CENTERS FOR DISEASE CONTROL AND PREVENTION

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH

ADVISORY BOARD ON RADIATION AND WORKER HEALTH

TELECONFERENCE OF SUBCOMMITTEE FOR PROCEDURES REVIEW MEETING

WEDNESDAY, JUNE 21, 2023

The meeting convened at 11:00 a.m.

EDT via video teleconference,

Josie Beach, Chair, presiding.

Vet Reporting

Certified Court Reporters

PO Box 72314

Marietta, GA 30007

678-646-5330 ext. 514

reporter@vetreporting.com
2 

Members Present:

Beach, M. Josie, Chair

Cassano, Victoria, Member

Valerio, Loretta, Member

Ziemer, Paul, Member

Registered Participants:

Roberts, Rashaun, DFO

Adams, Nancy, NIOSH contractor

Barton, Bob, SC&A

Behling, Kathy, SC&A

Buchanan, Ron, SC&A

Calhoun, Grady, DCAS

Carver, Mr.

Gogliotti, Rose, SC&A

Griffiths, Richard

Habighurst, Ashton, HHS

Mangel, Amy, SC&A

Sharfi, Mutty, ORAU

Taulbee, Tim, DCAS
3 

TABLE OF CONTENTS

Advisory Board on Radiation and Worker Health Teleconference of Subcommittee 

for Procedures Review Meeting Wednesday, June 21, 2023................................................. 1

Proceedings .......................................................................................................................................... 4

Welcome and Roll Call ................................................................................................................. 4

Carryover Items from February 16, 2023, Meeting......................................................... 6

PER-049 ......................................................................................................................................... 7

PER-092 ......................................................................................................................................... 9

Peak Street................................................................................................................................. 18

PER-73..........................................................................................................................................19

TBD-5000 ....................................................................................................................................31

OCAS-TIB-009...........................................................................................................................52

Newly-Issued SC&A Reviews ..................................................................................................65

OTIB-87........................................................................................................................................66

RPRT-0085..................................................................................................................................77

Preparation for August 2023 Meeting ..............................................................................92

Newly Issued Guidance and Supplemental Topics ......................................................97
4 

PROCEEDINGS

(11:00 a.m.) 

WELCOME AND ROLL CALL

DR. ROBERTS: Okay, so good morning, everyone. Welcome to the 

Advisory Board on Radiation and Worker Health. This is a meeting of the 

Subcommittee on procedures review. I'm Rashaun Roberts, DFO for the 

Board. There is an agenda for today. It's on the NIOSH website for this 

program under scheduled meetings for June 2023. You can find the agenda 

and all the presentations and other materials for today. 

Since the subcommittee will be discussing a number of different 

documents, some of which might involve specific sites, we do need to 

address conflict of interest. If a conflict does happen to come up during the 

course of the meeting, subcommittee members and others do need to 

recuse themselves from the discussion where their conflict of interests might 

apply. So, as we move through the roll call, subcommittee members and 

others please state where you have a conflict of interest. 

So, we'll start with the subcommittee chair, Beach. 

CHAIR BEACH: I'm here, and I'm conflicted at Hanford. 

DR. ROBERTS: Cassano? 

MEMBER CASSANO: I'm here. No conflicts. 

DR. ROBERTS: Valerio? 

MEMBER VALERIO: I'm here. All New Mexico sites, Pantex, and I 

believe Nevada test site is still on there. 

DR. ROBERTS: And Ziemer?
5 

MEMBER ZIEMER: I'm here, and I'm conflicted at Oak Ridge X-10. 

DR. ROBERTS: Okay. All right. It looks like all the members are 

here. Let's move on to DCAS and ORAU. 

MR. CALHOUN: Hi, this is Grady Calhoun. I am conflicted at the 

Fernald site. 

DR. TAULBEE: This is -- this is Tim Taulbee. I am conflicted at 

Mound. 

MR. RUTHERFORD: This is Lavon Rutherford, and I'm conflicted at the 

Fernald site. 

MS. MARION-MOSS: Lori Marion-Moss, and I'm conflicted at the 

Mound.

MR. SHARFI: Mutty Sharpie, conflicted at the Mound. 

DR. ROBERTS: Okay. Anyone else for DCAS/ORAU? Okay. Let's 

move on to SC&A. 

MR. BARTON: Bob Barton, no conflicts. 

MR. ANIGSTEIN: This is Bob Anigstein, no conflicts.

MS. BEHLING: Kathy Behling, no conflict.

DR. BUCHANAN: Ron Buchanan, conflict at Los Alamos. 

MR. CARVER: Joseph (ph) Carver. I'm conflicted at Oak Ridge and 

Savannah River. 

MS. GOGLIOTTI: Rose Gogliotti, no conflicts. 

MS. MANGEL: Amy Mangel, conflicted at Pacific Northwest National 

Laboratory. 

DR. ROBERTS: Anyone else for SC&A? 

MR. GRIFFITHS: Richard Griffiths, no conflicts. 
6 

DR. ROBERTS: Okay. Anyone else for SC&A? Okay. Let's move on 

to HHS and contractors. 

MS. HABIGHURST: Ashton Habighurst, no conflicts. 

MS. ADAMS: Nancy Adams, NIOSH contractor, no conflict. 

DR. ROBERTS: Any other HHS folks or contractors? What about the 

departments, DOL or DOE, other departments? 

DR. ROBERTS: Okay. Are there any members of the public who want 

to register their attendance? 

Well, thank you and welcome, again. I do need to go over a couple of 

additional items before I give the floor to Josie Beach who chairs the 

subcommittee. So, in order to keep things running smoothly and so that 

everyone speaking can be understood, everyone please be sure to keep your 

phone on mute -- of course, unless, of course you're speaking. If you don't 

have a mute button, press star six to mute. If you need to take yourself off 

mute, press star six again. 

The agenda, the presentations, and background documents that are 

relevant to today's meeting can be found on the NIOSH/DCAS website. As I 

mentioned before, all of these materials were sent to Board members and to 

staff prior to this meeting. 

So, with that, Josie, I will go ahead and turn the meeting over to you. 

CARRYOVER ITEMS FROM FEBRUARY 16, 2023, MEETING

CHAIR BEACH: Okay. Thank you, Rashaun, and good morning, 

everyone. Thanks, Kathy, for sharing the agenda. I do want to make note, 

there is one item on the agenda that's not correct. It's under carryover 
7 

items b,

providing an additional case for SC&A. That that shouldn't have been 

on there. I believe it was just copied and pasted. So, other than that, any 

other changes that we need to make to the agenda? Any other movement? 

All right. I don't believe we got anything for the first three items. And 

I'm assuming NIOSH is just going to walk us through those; is that correct, 

Lori or Tim? Our first item -- 

DR. TAULBEE: That is correct, yes. 

CHAIR BEACH: -- PER-49. Okay. Well, are you -- who's going to 

carry that? 

DR. TAULBEE: PER-49 is actually going to be Lavon. 

MR. RUTHERFORD: You got a lot of noise back there. 

CHAIR BEACH: Somebody's got some sirens going. 

DR. ROBERTS: If everyone could, please, mute their telephone unless 

they're speaking. 

PER-049

MR. RUTHERFORD: All right. I think we got that done. Well, this is 

LaVon Rutherford. And for PER-49, we were asked to provide some 

information in response to -- I've got to pull it back up here. -- basically, a 

write-up on why the -- you know, it changed when the original estimate was 

done with OTIB-2, and then we did the -- when we did the PER, OTIB-2 had 

been cancelled, so we change that dose assessment to use the actual urine 

bioassay data that was for that individual. And the question that came up 

well, why was the -- basically, why was the intake so high given that they 

were using the urine bioassay instead -- versus the overestimate. And we 
8 

provided a response to that. We sent that response to Kathy Behling. We 

also sent the -- we provided the inv files and the -- for a -- a -- the inv files 

and the actual xl files for using the bioassay data and not doing such a huge 

overestimate. So, we provided all that information to SC&A. I haven't 

heard a response yet on that. 

MS. BEHLING: And this is Kathy Behling. Yes, we initially did request 

the inv data, and we have a team of people looking at this right now just so 

that we can all convince ourselves and have a complete understanding of --

of what the differences were. And then the inv files, after we looked at 

those, we had some additional questions and in, I think, the beginning of 

May, I contacted LaVon again and asked for some additional data, which he 

did provide. However, since we didn't get that data or the requested data 

until the beginning of May, we have not, as a team, been able to come to 

any conclusion yet because we're just starting to look at that data. But we 

will have some response definitely for the next meeting. 

CHAIR BEACH: Okay, that sounds good. So, that takes us into the

hypothetical intakes. All -- all the stuff that we talked about last meeting, 

correct? 

MS. BEHLING: Correct. Yes, -- 

CHAIR BEACH: Okay. 

MS. BEHLING: -- Josie. That was the presentation that I made and as 

LaVon indicated, this came up -- this is -- this is on our agenda because 

during our presentation to the full Board, there were some questions. 

Actually, when we look at the PER, we were looking at external doses, but 

we took note of the fact that the hypothetical intake ended up being less 
9 

than the actual bioassay datas -- data, and so we brought that to the 

Board's attention, and they asked for a follow up. And that's -- 

CHAIR BEACH: Right. 

MS. BEHLING: -- where we are with that. 

CHAIR BEACH: Okay. So, that'll carry over to the next meeting with 

SC&A as the as the lead on it. 

MS. BEHLING: That's correct. Yes. 

CHAIR BEACH: Okay. Thank you. 

Any questions or comments, subcommittee members? All right. 

Hearing none, I think we can move on to the next item, b, which is PER0092. 

PER-092

CHAIR BEACH: I think NIOSH was to provide written response to 

observation 4 and finding 1. I didn't see anything, so I don't know if that 

got done or if you're just going to walk us through that. NIOSH? 

MS. MARION-MOSS: Yes, this is Lori, Josie. 

CHAIR BEACH: Hi, Lori. 

MS. MARION-MOSS: Hi. I did provide a written responses to the one 

finding and the four observations associated with subtask 4 for this 

particular PER. Basically, what I was -- what I provided SC&A was the -- a 

write-up of that Scott Seibert's (ph) responses during the last committee 

meeting, and that was -- 

CHAIR BEACH: Okay. I didn't -- I didn't see that, so I didn't realize 

that had gone out. 

MS. MARION-MOSS: Oh, I apologize. I sent that out to Kathy, and we 
10

have not seen a response to those, if any's required. But the sub asked that 

we put back responses in writing -- 

CHAIR BEACH: Right. 

MS. MARION-MOSS: -- purposes, and that was done. 

CHAIR BEACH: Okay, great. Kathy, any -- was it clear? Any 

comments? I think we were able -- we wanted to close it out, but you guys 

wanted to look at the writing -- 

MS. BEHLING: Yeah. And in fact, we've been going on the directions 

here. PER-92 is the Weldon Springs Plant. And Lori, did you put that out on 

the virtual volume -- volume? I have to -- I'm trying to recall. 

MS. MARION-MOSS: No, that was provided -- 

MS. BEHLING: (Indiscernible) -- 

MS. MARION-MOSS: -- in the email on June 6th. 

MS. BEHLING: Okay. All right. Ron, I guess you did not have an --

did you have an opportunity to look at that, Ron Buchanan? Are you on the 

line? 

DR. BUCHANAN: Yes, I'm on the line. This is Ron Buchanan. And 

yes, what that consisted of, I received that email, and what NIOSH had done 

was to finding 1 was we found that NIOSH assigned external dose to the 

constant distribution. When PER-92 said differently, and their response was 

NIOSH agrees that applying the maximum of the average is not necessarily 

maximizing when using a content distribution. Instructions to dose retract --

constructors does say to use the normal distribution. We have looked into 

this matter and discovered there were nine claims with this error -- error. 

All claims had less than one percent POC, so there is no impact whatsoever. 
11

Additionally, we are updating the DR tool such that a warning is issued 

to dose reconstructors reminding them of the use of the normal distribution. 

So, NIOSH did look into that finding and found out that there was an error, 

and that they look back at other claims for Weldon Springs that was 

supposed to use this distribution and found -- and reworked the claims and 

found that there was less than 1 percent POC and it didn't impact, and 

additionally, they're updating their tool. And so, that was finding 1 that we 

had -- had. 

Now, we hadn't given any response -- formal response to that. It 

sounds reasonable. I guess my question to NIOSH is when you went and 

reworked -- did you rework the claims or just look at them and say oh, 1 

percent, we don't need to rework them? 

CHAIR BEACH: Tim has his hand up, so I think he has a comment on 

that, possibly, or something else, Tim? Can't hear you. 

DR. TAULBEE: Sorry, I forgot to -- the mute person. Anyway, sorry. 

I don't have a response to Ron on that because I'm actually not sure as to 

whether, you know, we went back and reworked the entire claim or just 

looked at that 1 percent. But I did want to ask, would it help if I put up the 

actual email that Lori sent in -- 

CHAIR BEACH: Yeah, I -- 

DR. TAULBEE: -- right now? 

CHAIR BEACH: Yeah, I don't think everybody got that. I don't know. 

Lori, did you send that to the -- to everyone or just to Kat -- to SC&A? 

MS. MARION-MOSS: I just sent that to Kathy. 

CHAIR BEACH: Okay. Yeah. 
12

UNIDENTIFIED SPEAKER: Kathy, -- 

MEMBER ZIEMER: Yeah, this is Ziemer. I -- I looked in my emails. I 

didn't receive any on June 6th. 

CHAIR BEACH: Yeah. 

MEMBER ZIEMER: But I do -- I do think we need to have it in the 

record formally. 

CHAIR BEACH: Yeah, I -- 

MS. BEHLING: That's what -- my apologies for not putting that up. 

Thank you, Tim. 

DR. TAULBEE: So, now you all can see that email, which Ron was 

going for. And Ron, I'm sorry, I don't have an answer from that as to 

whether they -- whether OURA looked at the full -- reworked the full claim 

or just looked at the -- the PC. 

DR. BUCHANAN: Okay. 

DR. TAULBEE: I don't know if anybody on the -- that's on from ORAU 

knows that off the top of their head or not. If not, we can get back to you 

on that. 

DR. BUCHANAN: Okay. What I suggest then, get back on that. And 

then I'd like to cover observation 1 through 4, because I think we can close 

those out. What this was, was they weren't -- of course PER-92 had to do 

Weldon Springs. And we reviewed some cases, 2 cases, and had these --

had that finding which we just covered and are the observations 1 through 

4. 

Now, observation 1 through 4, we flagged those as observations, 

because in the rework of the cases, it was not stated, you know, specifically 
13

in the DR that there was an overestimate. And now, they were less than 45 

percent, so NIOSH says they were an overestimate, and that's fine. But 

when we did review, we just flagged them as a dose reconstruction 

observation in that observation 1 they used -- did not use a dose recon -- a 

(indiscernible) prostate. It was less than 1. They used 1 and used it as 

overestimate. And they said that they did that because the POC was less 

than 45 percent. We would agree with that on an overestimate, but we 

pointed out in a normal dose reconstruction, you wouldn't do that. 

And observation 2 did not -- NIOSH did not always incorporate the 

date of cancer diagnosis. Same explanation there. And then observation 3 

did not include the diagnosis date -- date for cancer one for external dose, 

external ambient dose, same explanation. And for cancer one for 

environmental dose didn't include the date of diagnosis. In other words, you 

know, they -- they carried the dose all the way through the end of the year, 

as opposed to -- say the cancer occurred in June and just assigning half the 

year of dose. And in an overestimate, that's true, like I say, it didn't 

specifically state that, so we flagged it as an observation, which in normal 

DR you would prorate those -- those values.

So, we have really no issue on observation 1 through 4 because they 

were an overestimate and which is done in that case, if -- it stated they 

were doing an overestimate.

And on finding 1, we would just like to know if the POCs were 

recalculated or if they just looked at them. And I would like to see an 

example of one of those. I think that they -- SC&A doesn't need to look at 

all nine claims. I'd like to see an example of one of those that they 
14

reworked, and then we can write up an email -- since this came in form of 

email, we can just write up an email with our response to the whole group, 

including the members of the subcommittee. 

CHAIR BEACH: (Indiscernible) -- 

DR. BUCHANAN: Kathy, you want to add anything to that? 

MS. BEHLING: No, Ron. The only thing I was going to ask the 

subcommittee is, are you in agreement that we can close the four 

observations? 

CHAIR BEACH: I -- this is Josie. I have no trouble closing the four 

observations. I would like this email sent out to all of us if possible. 

MS. BEHLING: Yeah, I apologize -- 

CHAIR BEACH: Lori, -- 

MEMBER ZIEMER: This is -- 

MS. MARION-MOSS: I can get that email. 

CHAIR BEACH: Okay. 

DR. TAULBEE: I would like to -- 

MEMBER ZIEMER: This is Paul. I -- I'm okay in closing those as well. 

CHAIR BEACH: Loretta? 

MEMBER VALERIO: I'm okay with closing those as well. Thank you. 

CHAIR BEACH: And any other comments on that? 

MS. BEHLING: Is Tim trying to (indiscernible)? 

DR. TAULBEE: Yes. I'm trying to address finding one a little bit here. 

Because when Scott was through this back in February, he indicated that, 

you know, the -- you know, he went through, and they looked at all the 

claims that had this error. And if it was, you know, the result of the 2 BRS 
15

and there's no impact as shown here, all the claims were less than 1 

percent, and, you know, those BRS had been cancelled. And I have a note 

here that this subcommittee actually closed finding 1 and just wanted to see 

this in writing back in February. 

CHAIR BEACH: Yeah, I think I would agree with that, but I think once 

the writing came out, and Ron has an additional question, I think we should 

follow through with that, which is why we asked for it in writing. 

DR. TAULBEE: Okay. I mean, we can here, but if the PC is less than 1 

percent, you know, whether they just looked at the PC 1 percent or whether 

they reworked this whole claim, it's really not going to change this, because 

we're talking about whether it was a constant or whether we assigned the 

normal distribution. So, this is really a small error that we've already 

corrected. And, yes, we can go through and do this and respond. If that's 

what you want, we will do so, but I really think this can be closed as is. 

MR. BARTON: This -- this is Bob -- 

CHAIR BEACH: Ron, -- 

MR. BARTON: -- Barton. Based on my notes from the last meeting, 

basically, what we were looking for was, again, in writing, basically a BRSstyle entry just to document the discussion from back in February, so I think 

that's consistent with what Tim just said. So, I think it was generally 

accepted, we just wanted it -- to have it officially in writing for when the BRS 

comes back so we can update it as such and track it so it's documented. 

MEMBER ZIEMER: Josie, this is Paul again. My notes from the 

February meeting, I -- I show that it was recommended to close but was put 

in abeyance. And that means that, I think, we're satisfied with it, but we 
16

wanted to see that final wording that you're talking about. 

CHAIR BEACH: Yeah. Yep, I agree with that. Ron, comments on 

that? Are you -- 

DR. BUCHANAN: My -- 

CHAIR BEACH: -- comfortable with that? 

DR. BUCHANAN: Yes. This is Ron with SC&A. Yes. If the Board is 

okay with that. I know, you know, just from a dose reconstruction point of 

view, it's not going to change the outcome of the cases, and so I really don't 

have a problem with that if the Board's satisfied with it. We can carry it 

through, and I can look at one of those or if you're satisfied that they did 

their due diligence, then I have no issue with it. 

CHAIR BEACH: And we already know you're changing the tool at this 

point; is that correct, Tim? That's underway? 

DR. TAULBEE: That is correct. Yes. 

CHAIR BEACH: Okay. Victoria, we haven't heard from you. Or what's 

your thoughts, anything? 

DR. ROBERTS: And I'm hearing some noise in the background. If 

people could, please mute their phones. 

MEMBER CASSANO: Were you asking me for my -- 

CHAIR BEACH: Yeah, if -- 

MEMBER CASSANO: -- input on it? 

CHAIR BEACH: -- comments or questions. 

MEMBER CASSANO: As long as the principals involved in this have no 

issue with it, I am fine at this point. 

CHAIR BEACH: Yeah, -- 
17

MEMBER CASSANO: If NIOSH and SC&A were in agreement, then I'm 

okay.

CHAIR BEACH: Gotcha. I -- I know Ron would like to look at another 

case, and I -- I don't know how much trouble that would be for you guys, 

Tim, to let them take a look at something. 

DR. TAULBEE: Well, normally, this would simple, but as you -- as you 

know, it's all the IT issues, it ends up becoming more difficult. So, I mean, 

it's doable. We can do it. But is it really necessary, is, I guess, what I'm 

questioning here. 

CHAIR BEACH: Okay. Well, hearing Ron said he would like to but it's 

not necessary if the -- if the subcommittee's comfortable, Paul, Loretta, you 

comfortable with just closing as is? 

MEMBER ZIEMER: This is Paul. I'm comfortable with that. I assume 

we'll have -- have the final information in writing at least in the record, so 

that's all we need. 

CHAIR BEACH: Okay. I'm fine with that also. Loretta? 

MEMBER VALERIO: I'm fine with that, Josie. I'm good with that. 

CHAIR BEACH: All right. We'll go ahead and close this. We will -- we 

will get the final in writing sent to us and then, Ron, I think you're still going 

to send something or are we done? We were talking -- 

DR. BUCHANAN: No, no, I'm okay. That's okay. 

CHAIR BEACH: Okay. 

DR. BUCHANAN: If you want us to send an email out, we can, or if 

you want to use this post that you had to close it out, that's fine too. 

CHAIR BEACH: I think we can just go ahead and close it out. I would 
18

like to have this for the record though, the email that Lori had sent out 

earlier. 

DR. BUCHANAN: Yes, that's important. 

CHAIR BEACH: All right. Thank you. 

MS. MARION-MOSS: Josie, this is Lori. I will forward this email to all 

Board members -- 

CHAIR BEACH: Okay. 

MS. MARION-MOSS: -- including, and I could also move it into the 

ECP if you like. 

CHAIR BEACH: Sure, that would work. That's what -- I had gone on 

the virtual volumes and looked and didn't see anything new for the meeting. 

So, yeah, if you put it there, that's fine. 

MS. BEHLING: And Josie, I will also update the BRS with their 

responses and our discussion today. 

CHAIR BEACH: Okay. The -- 

MS. BEHLING: The temporary -- 

CHAIR BEACH: The temporary BRS? 

MS. BEHLING: Yes, the temporary BRS. Uh-huh. 

CHAIR BEACH: That sounds great, thank you. Sounds like we might 

be getting closer to the real BRS, but not sure yet. 

PEAK STREET

All right, and if everybody's ready, our next item was Peak Street, and 

NIOSH was going to provide additional cases, and I believe the additional 

cases were provided; however, I don't think the subcommittee saw anything 

on that. So, I believe this is in SC&A's court right now? 
19

MS. BEHLING: Yes, this is Kathy. We did receive two additional 

cases. They came in somewhere mid -- about April 23 or fourth, something 

like that. So, we will start looking at those. And as we did with the previous 

two cases, I think we will present that to the subcommittee in the form of, 

perhaps, a -- a memo. I think Doug is going to be working on that. And if 

that's okay with you? 

CHAIR BEACH: Yeah, that's fine. 

MS. BEHLING: Okay. And perhaps -- 

CHAIR BEACH: And so, we'll see that possibly for the next meeting? 

MS. BEHLING: Yeah, possibly. Uh-huh. 

CHAIR BEACH: Okay. Anything else on that? And if not, we can 

move on to -- I think Ron's ready for Birds -- or do you have -- on PER-073, 

Ron, did you have a presentation or just the write-up you sent us, just the 

memo? 

MS. BEHLING: And that is actually Bob Anigstein. 

CHAIR BEACH: Oh, okay. Sorry. 

MS. BEHLING: That's okay. And Bob, are you on the phone?

PER-73

MR. ANIGSTEIN: Yeah, this is Bob Anigstein. I'm ready to talk about 

PER-73. 

MS. BEHLING: Okay. Do you want me to show that or are you going 

to show -- show it? Would you like -- 

MR. ANIGSTEIN: Excuse me? 

MS. BEHLING: Would you like me to display that on the screen? 

MR. ANIGSTEIN: Sure. Just my -- the memo. 
20

MS. BEHLING: Just the memo. 

MR. ANIGSTEIN: Right. Okay. I'm pretty much gonna talk from that. 

Okay. What happened with the PER-73, this goes back to, I believe, around 

2017-2018, where there were only four claims for -- for -- four cases that --

that were submitted as claims. And once we -- the report on -- the PER 

review included -- 

CHAIR BEACH: Bob, can you hold on -- 

MR. ANIGSTEIN: -- seven observations and one finding. And now -- 

CHAIR BEACH: Bob, -- sorry, Bob. Kathy, were you going to put that 

on screen? So far, I only see the agenda. Kathy, are you there? 

MS. BEHLING: Yes, I'm here. I'm sorry. I was on mute. I thought 

that I had the -- I thought I was sharing this. 

CHAIR BEACH: Yeah, so far, it's just the agenda, so thank you. 

MS. BEHLING: Okay. Let me see if we can put that up. Are you --

okay. Yeah, -- 

CHAIR BEACH: I have -- I actually have it up on my other computer, 

but others might want to see it. 

MS. BEHLING: There it is. Do you see that? 

CHAIR BEACH: No, it says -- nope -- there it is. Yep. Now it's up. 

Thank you so much. 

MS. BEHLING: Sorry. 

CHAIR BEACH: And sorry to interrupt, Bob. All right. 

MR. ANIGSTEIN: I'm pretty much going to read -- summarize -- 

CHAIR BEACH: Sure. 

MR. ANIGSTEIN: -- I mean, I'm -- pretty much from the memo, so I 
21

don't know if the screen display is -- add -- adds anything additional. I don't 

have the screen up right now, so I'm just talking from my -- 

CHAIR BEACH: Well, that's okay. 

MR. ANIGSTEIN: -- printout. 

CHAIR BEACH: -- but others might want -- others might want to see 

it, so that's why I wanted to make sure it was up. No, Bob, go ahead. 

You're good. 

MR. ANIGSTEIN: Okay. Let me know when I should go ahead. 

CHAIR BEACH: Yeah, go ahead. 

MR. ANIGSTEIN: Okay. What caught -- what caught the attention of 

the program was discovered -- we have as the -- two of the Board Members 

(indiscernible) have copious experience with a company called GSI, stands 

for General Steel Industries, who had an iron foundry -- a steel foundry, 

sorry, Granite City, Illinois. And you -- due to some activism on the part of 

one of the claimants or family member of one of claimants, we got copious 

information on that site. There were a number of workers still living in the 

area who had retired, who had survived, and there were meetings. And we 

had a great deal of information. 

And then we found Birdsboro had a very similar history and this 

caught the attention of the program. Both facilities use betatrons to X-ray --

to -- to radiograph castings for are -- they had contracts with the US Army 

for -- to provide Army tanks or (indiscernible) of Army tanks do -- during the 

Korean War in the '50s. And so, it was natural to assume well, maybe 

they're similar. 

The reason they came under the aegis of this program is that they also
22

handled uranium connected with the nuclear weapons program preparing 

uranium samples, eventually for use in the Hanford Reactor. We know very 

little about what they did with the uranium, but it was enough to put it in the 

program and to have a part of 1951 and all of 1952 was part of the AWE 

program. 

And so, it seemed the exposure -- the directly -- the external exposure 

for uranium, as everybody realizes, is not very large. There were not very 

copious amounts of uranium. However, the same workers that handled 

uranium might well have been exposed to radiography sources. So, in the 

initial finding, we assumed that the radiography sources, including the 

betatron and an X-ray machine, could have been subjected to the same 

workers who had done work with uranium to additional external dose. 

However, NIOSH did some further research on this and came up with a 

document that we were not aware of at the -- did the original work that 

there was a separate facility built for the radiography of the Army tanks. So,

there was a 250, I think, kVp X-ray machine and a 24 -- at that time, there 

was only 22, actually, megavolt betatron. However, we're satisfied with the 

NIOSH presentation that the -- those were separate. It was 500 yards away 

from the main Birdsboro foundry, and they had separate payrolls even 

though it was for -- for business purposes, they freely intermingled with 

each other and jobs -- jobs shifted back and forth. 

But we'll concede that it's probably likely that the betatron that --

unlike the case at GSI, where we came across one surviving worker, not a 

claimant who had the interesting job that he was a working in laboratory 

during the week, but he had the qualifications and experience and on 
23

weekends, he moonlighted for the same company as a radiographer. So, 

here was an example of somebody who might very well have been exposed 

to uranium and also might very well have been exposed to external radiation 

during radiography. And if such -- if this person -- there always some 

hypothetical person who had -- who is now deceased, his family may not 

know about his additional work, the details of his work, so -- so, the decision 

was made at GSI that all workers, except there was those that are 

obviously worked in an office whose full-time job was administrative work, 

secretarial work, clerical, and so forth, would be assumed to have been 

operators of radiography just to be on the safe side. So, it was natural 

during this review of Birdsboro -- well, maybe the same situation was there. 

Now, NIOSH -- I'm being repetitive now -- established that no, the 

radiography with the betatron was a separate operation, and it's unlikely 

that the same workers were exposed during the -- during that period. And 

we -- we concede that that's a reasonable assumption. However, at GSI, 

the greatest exposure was radium sources. Radium sources were used at 

GSI up until the mid '50s, late '50s, when the state radiation control 

persuaded them and pressured them to stop doing that because of the 

personal radiation exposure hazard. However, I had -- but that was -- that 

came later. That came in the late '50s. 

At Birdsboro, by reviewing the case, the individual cases brought by 

SC&A, myself, we found that there was one worker who is now -- one 

deceased worker whose family was interviewed as part of the CATI (ph) 

program, computer -- I think they use a different acronym now, but it was 

originally called the computer assisted telephone interviews. And he had --
24

there were a number of surviving claimants, and they all uniformly said that 

their parent was -- used cobalt 60 and radium sources for radiography 

during the coverage period. He was employed before, during, and after the 

covered period. And he -- they have and they even -- they didn't furnish, 

but they said there was a photograph of him using radium source or at least 

a mock up at that moment using the fishpole technique. 

Now, the fishpole sounds like just like a -- makes you think of Mark 

Twain Tales of Mississippi -- a long pole, maybe -- maybe five-six feet long, 

like I say, pole, a string tied to the end of the pole, and the other end of the 

string with a hook or some such, was a radiation source, an isotope source, 

and the most potent source from a radiation dose standpoint would have 

been Radium-226. And there was no shielding. I mean, the -- when it was 

not in use, the source was kept in a lead shield with a hole in it where your 

only -- unless you stood right above it, you will not get any (indiscernible) 

radiation exposure. 

But during the placement -- but then they had to use, take the pole, 

walk over to where the casting was, put the source in the designated spot, 

put the film behind the casting, and take a radiograph. And there was a 

very significant radiation exposure. We did the -- the MCMP analysis for the

GSI, and not knowing any other details except what I just gave you, I would 

assume -- we would -- SC&A would assume that, that was the potential 

source of exposure to this one worker that is family both in CATI interviews 

and also they -- each family member there was a survivor filled out a form 

provided by the Department of Labor. There was an employment history, 

and they all uniformly said that their parent was exposed to radium sources. 
25

So, then the other pieces -- so, we know at least one worker was a 

claimant who -- who was -- whose family were claimants. Whether it -- did 

use radium sources during the covered period during which he might have 

been assumed to have been exposed to the uranium also and never came 

out of the program. The second -- and then there was also -- there also as 

part of the claim, each of the survivors, the claimants, filled out an 

employment history form, and they all uniformly said that the parent was 

exposed to radium and cobalt sources.

Then the other piece of evidence that makes this a likelihood is there 

was a -- we have a -- SC&A has a former metallurgist who was working in 

the -- active in the -- in the 1950s, a later discovered period, and I asked 

him, was this a likely -- was it likely that they -- that since they were 

producing steel castings for various customers -- it was a large operation --

was it likely that they did radiography. And he said why don't you check on 

the ASTM Standard -- ASTM stands for American Society for Testing and 

Materials, the original name. Now it's called The ASTM International. And 

by doing the research, we found that, in fact, ASTM during the 1950s and to 

this day, would sell the radiography standards. What they were do is they 

would produce radio -- radiograph film, exposed films for sale to whoever --

whoever wants to buy it. And this was just changed over -- over a period of 

time. This is a minimum acceptable level of quality for your casting. 

And so, the foundry would -- a foundry, steel foundry, would have an 

agreement with the customers, not only would they ship them the casting, 

they would ship one with each casting -- we did -- GSI did that -- with each 

casting, they would fur -- furnish a radiograph, say, here is the X-ray film, 
26

just like medical -- I won't make the obvious comparison. 

So, then the question came up, was this a practice during the 1951-52 

period, and I we found on the website for ASTM, a description of the 

radiographs that were -- that were offered for sale for comparison purposes, 

and that there were -- depending on the -- there were different radiographs 

depending on the thickness. So, using the zero to 2 percent -- zero to 2-

inch -- excuse me -- radiographs, we found that there was a specific 

radiograph standard for radium sources. And it said it's not used anymore 

or rarely used, but at that time, there was one. Tt was called E-71. And the 

first edition of it was 1947, then it was two more additions later in the -- in 

the '60s. I forget the exact date now.

So, when you say therefore it was a common enough -- excuse me -- 

It was a common enough practice that ASTM was in the business of 

furnishing comparison radiographs. So, there wasn't -- I'm being repetitive. 

It was common practice at that time. Now, we don't have documentary 

evidence that Birdsboro, in fact, did that, but it's reasonable to assume that 

they would. Why would a customer who's paying for the casting not require 

that they -- proof of quality, that they show a radiograph that they made, 

Birdsboro would have made of their own casting. They would have 

compared it. They would have their own technical expert compare it to the 

one they purchased from ASTM as a reference and said okay, this is at least 

as good as every -- imperfections are no worse than the standard, and the 

standard we already have an agreement with our customer, that this would 

be an acceptable casting if it meets the standard. So, we say we know 

that -- so, we know that at least one employee was engaged in such work, 
27

and we also know that it was a likely practice at that time for a steel 

foundry. So, we believe that the possible exposure, potential exposure, to 

radium sources should be included in dose reconstructions for claimants 

from Birdsboro. 

So, any questions? 

CHAIR BEACH: Thanks, Bob. Any questions from subcommittee 

members? 

MEMBER ZIEMER: This is -- 

MEMBER VALERIO: I don't have any, Josie. 

CHAIR BEACH: Go ahead, Paul. 

MEMBER ZIEMER: Hi, yeah. So, I was on the -- actually, chair --

chaired the General Steel Industry's subcommittee. Bob described it very 

well. But that was a very common practice at that time. I -- I think, Bob, 

you're also suggesting maybe the -- the sort of modeling that was done at 

GSI might be transformable to Birdsboro. There -- there are some specifics 

at a site that has to be taken into consideration. But at GSI, for example, I 

think we had a longer work week than 40 hours, and you have to adjust for 

things like that. You also have to make some estimates as to how often 

such radiographs are made. And so there was a certain amount of 

modeling, actually a lot of modeling done at General Steel Industries to 

come up with a -- an exposure model for -- for the -- the workers there. 

They also had some issues on where things are stored and so on. But 

in any event, the likelihood of radium being present, in my mind, is -- is 

pretty -- pretty high. 

CHAIR BEACH: Yeah, and I was on GSI also. And -- 
28

MEMBER ZIEMER: That's right. 

CHAIR BEACH: -- remember those discussions. 

MR. ANIGSTEIN: Well, I would -- I would suggest that I didn't do a 

full blown-production on this. But there is a precedent for using surrogate 

data. In other words, if we don't -- if we have little information about the 

site in question, but there was another site where there is good information, 

we just say well, we will just assume, for lack of anything else. So, we know 

nothing about the details of the radiography except what I just presented at 

Birdsboro, but yes, Paul is entirely correct to call that, that there was -- they 

had copious documentation at GSI. There was one worker advocate -- I 

won't -- (indiscernible) from mentioning his name, but subcommittee 

members will know who I'm referring to -- 

CHAIR BEACH: Exactly. 

MR. ANIGSTEIN: -- was extremely diligent and active in recruiting 

former workers. So, we have a very good picture, and my understanding of 

the -- our program is that you can use surrogate data if it's the same period. 

GSI was active in defeat 1951-52 a period. It was probably their covered 

period also -- I think not '51. I think it started in '52. But anyway, that's 

pretty close. 

CHAIR BEACH: Yeah, I think we probably need to hear from NIOSH on 

what their thoughts are on your write-up. 

MEMBER ZIEMER: Yeah, exactly. And incidentally, at General Steel, 

there was some limited film badge data saying that associated with the --

with the betatrons, but in any event, probably a little better documented 

there. But again, the surrogate data issue could be considered. But yeah, 
29

you're right. We need to -- NIOSH needs to take a look at Bob's response 

and -- or SC&A's response and -- and see what they think. 

MR. ANIGSTEIN: I haven't looked at it -- I haven't looked at it 

recently, but my recollection is that the film badge -- the available film 

badge data from RS Landauer starts about 1960 when radium was no longer 

used. 

MEMBER ZIEMER: Right. And it was specifically in the cobalt '60 era, 

keeping in mind that during the radium -- radium is never controlled by the 

NRC, it was -- or the what was then the Atomic Energy Commission. It 

hadn't -- I don't believe the state at that time had any -- in the early '50s, 

the -- the Illinois regulatory group was not in action yet either, so. 

MR. ANIGSTEIN: Well, actually, I seem to recall, and it would be 

contentious, that they stopped using radium because the state would not 

allow it. We know the AEC was not involved with radium because it's not a 

reactor byproduct. 

MEMBER ZIEMER: Right. And most of the states stopped using it 

mainly because of so many of those radium sources were leaking. That was 

-- that was the -- one of the major problems was leaking sources. But in 

any event, those are other details that we probably don't need to spend time 

on. But in any event, yeah, eventually the states are the ones that halted 

the use of it. 

MR. ANIGSTEIN: Right, yes. So, unless there are any further 

questions, I rest my case on that. 

CHAIR BEACH: Thanks, Bob. NIOSH, any comments? 

DR. TAULBEE: Yes. This is Tim. We -- we got Bob's memo about 
30

two -- two weeks ago, and thankfully, you know, Bob and SC&A are 

concurring on the -- you know, the use of the betatron was in a separate 

facility. We will evaluate the Radium-226 and Cobalt-60. In fact, we've 

already started doing so and will incorporate what we find from that 

additional research into our response to Bob's memo here, as well as the 

seven observations that we still owe you-all a response on. So, that's our 

plan for going forward. And we'll -- we'll update you at a future meeting. 

Thanks. 

CHAIR BEACH: Thanks, Tim. And no -- no suggestion when that 

might be ready? 

DR. TAULBEE: Unfortunately, -- 

CHAIR BEACH: (Indiscernible) -- 

DR. TAULBEE: -- no. Not at this time. I -- 

CHAIR BEACH: Okay. 

Dr. Taulbee: I -- I don't -- I -- I don't know. This is kind of -- a little 

bit of new information. We did do -- you know, have some, I believe, from 

the original finding, radium and Cobalt-60 was initially mentioned, and we 

focused on the betatron primarily in our first response. And we'll focus on 

the radium and cobalt specifically on this one. 

CHAIR BEACH: Okay, sounds great. I guess we can carry it over. And 

if you're not prepared, you can let us know when the agenda comes out for 

the next meeting. 

DR. TAULBEE: That sounds good. Thank you. 

CHAIR BEACH: All right. Thanks, Tim. Any other follow up on 

Birdsboro? If not, thank you, Bob. Appreciate your thorough summary. 
31

And we do have the one finding, and as Tim stated, the seven observations, 

so we will just carry that over. 

TBD-5000

CHAIR BEACH: If there's no other comments, we can move on to 

TBD-5000. I'm not sure quite where we are on that. I know we had a paper 

from SC&A last March. I don't know -- 

MR. ANIGSTEIN: That is correct. Yes, that is a memo dated March 

27th. 

CHAIR BEACH: Yeah, -- 

MS. BEHLING: Josie, this is Kathy. I'm sorry. I'm trying to share that 

on my screen. Are you seeing it? 

CHAIR BEACH: Yes, we are. 

MS. BEHLING: Okay. Okay, great. So, Bob, we are going to present 

that when you're ready. 

CHAIR BEACH: Okay. And I'll turn that over to Bob. Thanks. 

MR. ANIGSTEIN: All right. Now, the -- made one presentation at the 

September -- last September's meeting, and we had 13 observations on --

for the benefit of anybody who -- just very quickly, Battelle 5000 was a 

procedural document that was produced in, I believe, 2007. And I'm just 

looking at my -- yeah. And it was apparently -- had fallen into disuse, but 

the subcommittee showed -- saw that it was still -- technically it was still 

active, or it could have been used for dose reconstructions. And 

consequently, we were tasked with reviewing this. And we did a fairly 

thorough, I think, review. It's a fairly long document. 

And it resulted in 13 obser -- our review disclosing 13 observations. 
32

So, I will go through the -- my question for subcommittee is five of the 

observations were closed at the last meeting, should I mention them, or 

should we just skip over them and just use -- just talk about the ones that 

were not closed? 

CHAIR BEACH: Yeah, if we -- if we closed them, let's skip over them, 

if everybody's in agreement to that? 

MR. ANIGSTEIN: Okay. 

CHAIR BEACH: Yeah. 

MR. ANIGSTEIN: All right. In that case, I will start with observation 

two. Observation two has to do with the resist -- the ROS method, 

regression and order of statistics, which deals with what happens if you have 

a set of data, set of measurements, and some of them are censored. By 

censoring, they fall -- mostly they fall below the limit of detection, the LOD. 

So there is -- they're recorded, we may even have values for them, but 

they're not reliable values because the instrument and a methodology used 

simply could not reliably detects such low values. In a few less common 

cases, that will be -- and so these will be the left sensor. The data reads 

from left to right, so the left -- and the left-hand, some of them would be 

blanks. 

Likewise, it's conceivable sometimes that the measurements exceed 

the limits or is it that the count rates will be so high that the instruments 

cannot reliably report them, so those because the right sensor. That's a less 

common -- so they were using this ROS method, and there was a criticism --

not really the most up-to-date methodology. The ROS method, essentially, 

conceptually, you fit the data to a lognormal distribution, and then you just 
33

take into account the fact that there are some off to the left, data points that 

are often not on the graph and it adjusts the other -- the other readings to 

account for that. 

So, NIOSH responded that there are more method -- more modern 

methods, and they presented three reports and -- including one that we 

actually had recommended in our initial review. A statistician, it -- textbook 

article called Helsel, H.E.L.S.E.L. And so, NIOSH actually mentioned, yes, 

that's one of the methods that they are now using. They are not using the 

initial ROS method. So, we're satisfied that they have -- that they answered 

the observation by saying they're no longer using that method, they're using 

a different method, the multiple imputation method. And they actually 

referred to Helsel and the -- R package is called NADA -- NADA. And so, 

we're satisfied that they replaced the method. We did not do a deep 

analysis of that because that would be out of scope. But we did say that the 

multiple imputation method has replaced that. And therefore, we 

recommend that the observation two be closed. 

CHAIR BEACH: Okay, thanks, Bob. Let's go ahead and talk about that 

and take action before we move on. Other subcommittee members agree 

with that recommendation? 

MEMBER ZIEMER: Josie, this is Paul. I certainly agree with that one -- 

CHAIR BEACH: Thanks. Perfect. 

MEMBER ZIEMER: -- that we should close. 

CHAIR BEACH: Okay. Thanks. 

MEMBER CASSANO: Yes, and -- 

CHAIR BEACH: Victoria? 
34

MEMBER CASSANO: Yes. I agree with that, with the 

recommendation. 

CHAIR BEACH: Thank you. And Loretta, you okay with that as well? 

MEMBER VALERIO: Yes. 

CHAIR BEACH: Okay. So, I think we're all in agreement. I agree also 

that we take SC&A's recommendation and close observation two. 

MR. ANIGSTEIN: Okay. 

CHAIR BEACH: All right. You can move forward. 

MR. ANIGSTEIN: Go on -- go on to observation four, which is 

something we found called the mirror, and there was two methods. Mirror 

image and preserved mean variance. This is something that we at SC&A are 

not aware of any technical backgrounds. Is this a good theory? This is 

something that -- without making serious comments, was sort of an ad hoc 

methodology, which is simply not part of the modern statisticians tool chest. 

And NIOSH responded that they are not -- that they agree. They are not 

using this methodology, that they have a new way they do -- way of 

handling normal noise and lognormal signal, which is a computational 

challenge, because it's well accepted that environmental samples and clinical 

samples follow -- typically follow a lognormal distribution. Whereas, random 

errors, what we call noise, just -- if you make the same measurement 10 

times, you get 10 different values. So, this is -- the -- these values follow a 

normal distribution. So, the question is how to combine the lognormal with 

the normal. And they have produced ORAUT report 96 multiple imputation 

applied to bio -- bioassay co-exposure models as a methodology for handling 

this situation, and therefore, they are not using the already -- the mirror 
35

image as a preserved mean and variance method. And consequently, we, 

without having -- we did not do an in-depth analysis of the new 

methodology, but we're satisfied that this is a methodology which avoids 

those earlier methods which we do not consider to be valid. And so, again, 

we recommend that the observation be closed. 

CHAIR BEACH: All right. Thanks, Bob. All in agreement with that? 

Anyone not in agreement, you can go ahead and comment. 

MEMBER ZIEMER: Well, I'll just comment that some of these 

statistical things are still a bit of a mystery to me. I'm very dependent on 

the -- the help of -- both of NIOSH and SC&A. And I'm confident that they 

have appropriately analyzed, and so I'm good with the agreement to close. 

CHAIR BEACH: Thanks, Paul. That -- 

MEMBER ZIEMER: Just be aware that I -- I -- I -- I -- I can't 

personally say that I fully understand that methodology, but that's -- on 

many of these things, we are dependent on the experts who we have 

employed to do this.

CHAIR BEACH: I -- I agree. And the comments under this one that 

they didn't -- that Bob didn't do an in-depth technical review, just 

fortunately for us, he didn't need to at this time. But I agree with you, Paul, 

it is -- we have to depend a lot on the experts. So, I'm in agreement with 

that. Victoria, Loretta, you good for closing? 

MEMBER VALERIO: This is Loretta. I'm in agreement, Josie. 

MEMBER CASSANO: I'm in agreement as well. 

CHAIR BEACH: Okay, thanks. So, we are in agreement to close, and 

Bob we can move on to the next item. I don't think you have answers for 
36

the five, six, and eight at this time, correct? 

MR. ANIGSTEIN: Excuse me? 

CHAIR BEACH: I said I -- I'm not aware of you that you had anything 

-- any written responses for five, six, and eight -- 

MR. ANIGSTEIN: Yes. For observation five, we're waiting for --

NIOSH said they in -- they intend to make -- to issue a separate report. 

Observation five, as a reminder, is that the TIB 5, the Battelle TIB-5000 

applies. There was a ICRP assessment of the ability of the ICRP publication 

30 modelled -- I'm sorry, I said that wrong. They did -- there was a -- there 

was an evaluation of the ICRP 30 models. What those -- that's something 

that goes back to the, if I'm not mistaken, 1970s, 1980s, and they applied 

that to the current ICRP 66 model and applied this -- the same critic --

criticism and uncertainty, and we flatly disagreed with that because the lung 

model -- it was a new lung model produced by the ICRP in report six --

publication 60, a thick volume that described it... So, it's just not valid to 

say well, whatever applies to the ICRP 30 model applies also to the ICRP 66 

model. And NIOSH announced that they will be producing a report on that 

very topic, but they -- we have not heard about it yet -- since. So, the 

subcommittee at the time of the last meeting agreed that the -- this remains 

open. So, and we, SC&A, was in agreement with that. So, it stays -- it 

stays open unless there -- there's no new developments that we are aware 

of. 

Then observations six -- is there any questions about observation five? 

Observation six overlaps observation five. It starts off with the fact 

that the GSD of 10 was applied taking the data from Christofano (ph) and 
37

Harris, which -- which is seven -- seven different plants, uranium 

enrichment, uranium randling (ph) plants, and they applied the GSD of 10, 

which is enormous to me, a factor of 10. You know, give it -- give or take a 

fact -- factor of 10. And that is, in our mind, too large to apply to a -- to a 

single situation, to a single client. And NIOSH agreed with that; however, 

they also said that they -- that they're using a GSD of 5 as a default value 

and DRs. We agree with that. That was part of part TBD-6000, which SC&A 

reviewed the two -- two different editions of it. We reviewed them both, I 

believe. And we agree that five is a reasonable number. 

But also, I have said that using GSD of 3 four biokinetic modeling, and 

we asked that they produce more data. They justify that and (indiscernible) 

that. The only justification that they came up with was an email, which no 

longer exists, no longer retrievable at the very, very beginning of our -- of 

this program in the early 2000s. So, that's not the -- that doesn't count 

anymore. So, the Board also -- the subcommittee also voted that the 

observation six should also be left open. 

Is there any -- any -- any questions or further discussion on six? 

DR. TAULBEE: This is Tim. If I could interject here, we are working 

on the report, and it's currently in development. And we expect to have it 

released by our project plan sometime in November.

CHAIR BEACH: Sounds good. Thanks, Tim. 

MR. ANIGSTEIN: Okay. So, I will go on to observation seven. 

CHAIR BEACH: Okay. Thanks. 

MR. ANIGSTEIN: Observation seven, was about a specific example of 

how to handle data. They had six measurements of an operation that took 
38

place -- it was assumed to take place at the Lake Ontario Ordinance Works, 

and there were radon measurements made. It was that they were opening 

covers, I believe, and removing covers from drums. And there was -- as it 

happened, there weren't -- on two different days -- two successive days, 

they were minutes apart with three measurements on each day, and of 

those six measurements, three were high, quite high, three were quite low. 

And they -- but they were not, like, one day and the second day; they were 

taken from the two days, three measurements were high and three others 

were quite low. And they assumed for -- as an example, calculation, these 

must be from separate populations, and we will treat them separate. We 

will -- instead of this being 24 minutes per shift -- let's say was 12 minute --

two 12-minute periods, one exposed to a low concentration, one is with a 

high concentration, and we find that not valid. The mere fact that the 

measurements are different does not mean that it's -- that the situation --

that they come from a different population and that this is not a valid 

application. And NIOSH's response was that they don't use this 

methodology, and that they have a specific procedure for evaluating radon 

exposures at the Lake Ontario Ordinance Works and they assume a -- based 

on measurements made, they assume a fixed value, the claimant's -- made 

a claimant-favorable assumption that there is a fixed value of radon -- fixed 

concentration of radon that the workers are assumed to be exposed to. 

So, we agreed that the methodology -- with NIOSH that the 

methodology in OTIB-5000 is not used anymore, and that there is a new 

methodology to replace it, which does not use statistics, it just uses fixed 

upper -- upper-end value of radon concentration. So, we recommend that 
39

the observation seven be closed.

CHAIR BEACH: Any questions subcommittee members? 

MEMBER ZIEMER: I have a question on this one. And I -- this may be 

a question for NIOSH, but what's the value to the bounding value in this 

case? That wasn't clear to me. 

DR. TAULBEE: Paul, could you repeat that please? 

MEMBER ZIEMER: I was asking whether or not the 108 picocuries per 

liter was considered by NIOSH to be a bounding value, or is this more of a

statistical average, or is -- what -- what is -- what is the identity of that 

number? 

DR. TAULBEE: Okay. Thanks for the clarification. I don't know. I'm 

gonna have to get back to you. Maybe if -- is there somebody online that 

might know that answer from ORAUT? I'm not hearing anybody speaking 

up. We'll have to get back to you -- 

MEMBER ZIEMER: Well, -- well, -- 

DR. TAULBEE: -- on that, I think -- 

MEMBER ZIEMER: This may be a geometric mean looking at the other 

information about the multiple categories, and they have a geometric mean 

for each category, and then they have this number. So, I was trying to 

relate the two or that the number to that identification of those three 

geometric means. So, I -- unless it's clear, I -- I don't know. Bob, do you 

have -- what is your understanding of that? 

MR. ANIGSTEIN: Well, I -- our conclusion was simply we did not 

confirm the value of 108, we simply took a more limited view of our task and 

said they are not using those -- that statistical method, which was the only 
40

objection. They're using something else now. We don't -- we were not 

tasked with every -- with a detailed review of the methodology for Lake 

Ontario. We -- were simply said that is the statistical analysis valid; we 

found it was not valid, but they're not using such a method. So, it's no 

longer an issue. So, we recommend observation seven be closed without 

passing on -- we did -- whether the current methodology for LLOW is, in 

fact, valid. 

MEMBER CASSANO: This is Tori Cassano. My -- I -- I -- I -- if I'm 

following this correctly, it sounds like we still have a lot of questions on this 

concerning the new methodology, so why would we be recommending 

closure? It's more questions than a comment. 

CHAIR BEACH: Yeah. SC&A wasn't actually tasked to review the new 

methodologies on these, just the Battelle TBD-5000, so that would be 

considered extra tasking, I believe. 

MEMBER CASSANO: Oh, well, I -- I'm not sure how to approach that 

then. 

CHAIR BEACH: Yeah. 

MEMBER ZIEMER: This is Ziemer again. I wasn't necessarily asking 

that -- that SC&A evaluate this. I -- I might be simply asking the basis for 

the 108 if -- if NIOSH is able to come up with that, I -- I -- I'm -- I think I 

may be suggesting that we just keep this open for -- for clarification. I'd like 

to be comfortable with where this 108 came from. 

CHAIR BEACH: Yeah, that's under -- 

DR. TAULBEE: This is Tim. 

MEMBER ZIEMER: And that I'll -- and I'll -- This probably was done 
41

somewhere else, and I either missed it or we -- we -- we don't have to solve 

it today necessarily, but just for -- maybe for my comfort level. 

DR. TAULBEE: -- I -- I pulled up the Lake Ontario Ordinance dose 

reconstruction methodology to try and get to this while we've -- we've been 

speaking here. And what this value is, this is for other buildings that they're 

on site that were not part of the K-65 residue. And 108 is a geometric mean 

with a GSD of 7 for that particular indoor value for radon. So, it -- it's not --

MEMBER ZIEMER: So, 108 is -- well, but it is the -- 

DR. TAULBEE: It's based upon -- 

MEMBER ZIEMER: It's the -- 

DR. TAULBEE: -- 12 samples. 

MEMBER ZIEMER: It is the geometric mean? 

DR. TAULBEE: That is correct, -- 

MEMBER ZIEMER: And it's a -- 

DR. TAULBEE: -- and it's based upon 12 air samples, and the GSD is 

7. 

MEMBER ZIEMER: Okay. That's -- yeah, that's pretty high. Okay. 

Okay, if that's the case, then I'm fine with that. That -- that certainly would 

be claimant favorable, too then. 

DR. TAULBEE: Thank you. 

MEMBER ZIEMER: That's where it came -- that's where it came from. 

CHAIR BEACH: Okay, thanks, Tim, for looking that up. We appreciate 

that. 

Paul, are you satisfied and comfortable with -- 

MEMBER ZIEMER: Yeah, yeah. 
42

CHAIR BEACH: -- closing that -- 

MEMBER ZIEMER: Yeah, that's -- that -- exactly satisfies me. Thank 

you. I am -- I'm okay for closing in that case. 

CHAIR BEACH: Okay. Others? I agree with the closing at SC&A's 

recommendation. 

MEMBER CASSANO: I'm good with that. 

MEMBER VALERIO: I'm good with that, Josie. 

CHAIR BEACH: Okay. We'll go ahead and close seven, and Bob you 

can move on to eight. 

MR. ANIGSTEIN: Okay. Observation eight is sort of a technical issue. 

It refers to the new methodology -- I mean, new a few years ago -- used by 

NIOSH and promulgated by NIOSH to evaluate inadvertent ingestion during 

the residual period, the AWE site residual period. And they have a 

procedure that was written by our former colleague (indiscernible) of doing 

inadvertent ingestion during the AW period, during -- during the active 

operations period. However, they found out that that is not really 

transferable to the residual period. 

So, they did come up with a new methodology and the equivalent of 

that is based on hand-to-mouth transfer. In other words, there is a 

contamination on surfaces that the worker encounters during the day, and 

some of that becomes ingested. And there are three different NUREG 

documents and all of which are NUREG CR documents. CR stands for 

contractor. And the position of the NRC on the -- on the new (indiscernible) 

is they simply paid for the -- for the research, and here it is, but the agency 

does not actually adopt it. So, there was -- the initial one was NUREG 5512 
43

SC&A was involved in critiquing it on behalf of NRC back in the 1990s. And 

it was considered volume one. It was authored by Kennedy and Strenge. 

And it contained a value based on very limited data publications of what 

should be the type D -- what area of the contaminated air zone should the 

worker be assumed to adjust? 

And then there was a revision to the 5512. Seven years later, the 

contract was given to -- the first one was the Pacific Northwest, then the 

contract was given to Sandia National Laboratories, different organization, 

different authors. They did a much more detailed study and came up with a 

fairly similar rate. But then there was a third one, NUREG CR 6 -- 6755. 

They came up with is still-different rate. So, we're talking about differences 

of a few percent. However, we feel it's important that there be a sound 

basis. And so, the -- the NUREG 55 -- NUREG CR 5512, volume three --

volume three is our estimation, a much, much better documented, much 

more detailed value and it comes out to not very different. So, the value --

the volume three val -- volume three value is 1.1 10 to the minus 4 meters 

squared per hour transfer. That seems like a very acceptable value. 

Now, doing some detailed statistical run, a different set of authors, 

NUREG CR 6755 came up with 1.12 times 10 to the minus 4 meter squared 

per hour. So, 1.2 and 1.11, there's a 2 percent difference. So, essentially 

more claimant favorable. Speaking for SC&A, we were very happy to accept 

either of these two values that NIOSH chooses to use -- not the one times 

10 to the minus 4. That was 10 percent lower and also not as well 

documented, not as -- not as well founded. 

And so, this discussion will take place at the last meeting, SPR 
44

meeting, in -- last September. And at that time, the subcommittee decided 

that they need more information as to which of the three values NIOSH is 

using. So, we have not heard back from NIOSH since then, so at that time, 

it was left open, and it's -- 

CHAIR BEACH: All right. Thank you. 

MR. ANIGSTEIN: -- still open. 

CHAIR BEACH: Right. Okay. Thanks. Tim, any comments on that? 

DR. TAULBEE: Yes. The current value we're using is 1.12 from the 

NUREG CR 6755, that is what we are currently using now. In the past we 

may have used 1 -- 1.1 or 1.0; we're actually not sure. But going forward, 

1.12 times 10 to minus 4 has been the most recent value that we have been 

using standardized across all the sites, and that's what we're continuing to 

use. If the subcommittee wants us to adopt SC&A's value at 1.1, that's fine 

with us as well. We could go either way. It really is -- it's such a small 

difference, you know, the 2 percent, it's really not going to make a huge 

difference. So, whichever it is that you-all prefer is where we'll go forward. 

But right now, we’re using 1.12. 

CHAIR BEACH: 1.12 and then 10 to the minus 4, right? 

DR. TAULBEE: That's correct. Yes. 

CHAIR BEACH: Comments on that, Bob, since you hadn't gotten that

before now? 

MR. ANIGSTEIN: Oh, that's -- that fine by SC&A. It's slightly more 

claimant favorable, and it has a valid justification, so we're -- we're -- we're 

comfortable with that. 

CHAIR BEACH: Okay. And recommending closing this at this time, 
45

then? 

MR. ANIGSTEIN: Yes. 

CHAIR BEACH: Okay. Other subcommittee members, are we in 

agreement with closing this out? 

MEMBER CASSANO: No objection. 

MEMBER ZIEMER: I agree. 

MEMBER VALERIO: No objection, Josie. 

CHAIR BEACH: Okay. 

MEMBER VALERIO: And just real quick, Josie, just to -- just real quick 

to clarify, NIOSH -- what Tim said was that NIOSH is currently using the 1.2 

times the 10 to the minus 4 value, that's correct? 

CHAIR BEACH: Yes, that is correct. 

DR. TAULBEE: One point one -- 

MEMBER VALERIO: Okay, thank you. 

DR. TAULBEE: -- two times 10 to the minus 4. 

MEMBER VALERIO: 1.12? 

CHAIR BEACH: Yeah. 

DR. TAULBEE: That's correct. 

MEMBER VALERIO: Okay. 

CHAIR BEACH: Okay. 

MEMBER VALERIO: Thank you. 

CHAIR BEACH: Yeah, and I see no reason to change that to SC&A's 

recommendation unless you-all want to, and it sounds like Bob's comfortable 

with the 1.12. Okay, we can go ahead and move on to -- 

MR. ANIGSTEIN: Yes. 
46

CHAIR BEACH: -- I think we -- 

MR. ANIGSTEIN: Okay. So, -- 

CHAIR BEACH: -- our next -- 

MR. ANIGSTEIN: -- we skipped -- 

CHAIR BEACH: -- (indiscernible) -- 

MR. ANIGSTEIN: -- that was observation eight. We skipped to 

observation 12, -- 

CHAIR BEACH: Okay. 

MR. ANIGSTEIN: -- the next open one. And observation -- 

CHAIR BEACH: I think -- I think nine is still open. 

MR. ANIGSTEIN: -- 12 -- 

CHAIR BEACH: Bob, I think nine is still open. 

MR. ANIGSTEIN: Nine? Nine, -- 

CHAIR BEACH: Yes. 

MR. ANIGSTEIN: -- 10, and 11 were closed. 

CHAIR BEACH: Oh, it says -- 

MR. ANIGSTEIN: -- at the last -- 

CHAIR BEACH: It says recommended that observation nine be closed, 

so, it doesn't show is closed. 

MR. ANIGSTEIN: No. I -- I have -- 

(Whereupon, multiple attendees spoke simultaneously.) 

MR. ANIGSTEIN: My record shows that SPR voted to close observation 

nine as a -- 

CHAIR BEACH: I'm just saying the write-up in your paper says -- 

DR. TAULBEE: Josie, it -- on the next page at the top, it -- 
47

CHAIR BEACH: Oh, yes, I see that. Thank you. Thank you. Okay. 

Moving on. 

MR. ANIGSTEIN: I'm sorry, I didn't hear... 

CHAIR BEACH: Now, I -- you can go ahead and continue. Thanks, 

Bob. 

MR. ANIGSTEIN: All right. So -- so, that brings us to observation 12. 

And 12 I was reading -- 12 was -- there was a basic misconception in OTIB5000 about how to handle thoron exposures. So, thoron, otherwise known 

as Radon-220 is pretty short lived, less than a minute. And the direction in -

- I'm sorry. Excuse me a moment. 

The direction in TIB-5000 is to assume a lognormal distribution with a 

mean value of .02 to represent an equilibrium factor. Well, there are two 

things wrong with that. One is that it's not the commonly accepted today, 

the equilibrium factor is much higher than that, but twice -- twice -- twice as 

high. And second, the concept of the equilibrium factor does not really apply 

to thoron. For -- for IREP input, for radon -- radon two -- a little confuse --

I'm gonna go back to the physicist and (indiscernible) method and simply 

refer to it as Radon-220 and Radon-222. Radon-222 is the more common --

commonly acquired radon exposure. 

So, the exposure -- the way I read (indiscernible) -- input -- IREP 

input is handled for radium -- Radon-222 is taking the measured 

concentrations and using -- relying on the data for uranium mining 

operations where there's copious data that shows the rate of lung cancer for 

a given radon concentration. Such data -- there's no such reliable good data 

for thoron. And consequently, the way that NIOSH now handles thoron is 
48

they don't use equilibrium factor. They do a dose calculation. Because the 

exposure to thoron cannot be -- cannot be evaluated based on the -- on the 

epidemiology of the exposures to radon. So, since they are no longer using 

that methodology -- we don't know if they ever did use that methodology --

we recommend that the observation 12 be closed. 

CHAIR BEACH: All right, any questions on that one? Everybody in 

agreement? 

MEMBER ZIEMER: Yes. 

MEMBER VALERIO: This -- 

MEMBER ZIEMER: -- looking for a response, yes, I agree, close it. 

MEMBER VALERIO: This is Loretta, I agree. 

MEMBER CASSANO: I agree. This is Tori. I agree. 

CHAIR BEACH: All right. I also agreed. Bob, we can go ahead and 

close 12 on your recommendation. 

MR. ANIGSTEIN: Yes. And then should I go on. 

CHAIR BEACH: Yes, please do. 

MR. ANIGSTEIN: Okay. And then the final one, observation 13, and 

let me just simply read the observation is that even if the true underlying 

distribution of concentrations were lognormal, there is no reason to believe 

that the distribution of the uncertainty parameter -- representative 

parameter is also lognormal, and that was touched on by one of the earlier 

observations also. And NIOSH -- well NIOSH responded but did not answer 

the question. It simply said that are more modern methods dealing with 

these uncertainty distributions and they are no longer using the method 

described by the Battelle TIB-5000. However, as the subcommittee 
49

observed, NIOSH has not -- did not state what method they are using. 

So, the subcommittee at that time, the last meeting, or the September 

meeting, voted to leave it open until NIOSH produces more information. 

DR. TAULBEE: Okay. This is Tim. I'm trying to figure out how to best 

answer this. The -- as noted, this particular method is not used in dose 

reconstructions. You asked for what methods are we using? Well, report 97 

is a good example of what we are using now. We tend to use more Monte 

Carlo methods for uncertainty and propagate it through Monte Carlo --

propagate uncertainty through Monte Carlo method. Report 97, SC&A has 

already been tasked to review. It actually deals with GA -- or BZ to GA 

sampling, which is what this particular section of TIB-5000 was dealing with 

and where this issue initially came up. So, that's an example of the methods 

we are using currently. So, if you look at report 97, there's multiple ways 

that the data is being combined in there and -- and that -- that is how we 

are doing the uncertainty these days, these -- using these modern methods. 

So, again, SC&A has already been tasked to review report 97. I know that's 

underway. I -- I would actually recommend that you close this, because it --

there's -- if there's an issue, that's where we should be discussing it is then 

with report 97, not in this particular case, for a method that we're no longer 

using -- 

CHAIR BEACH: Yeah. I -- 

DR. TAULBEE: -- or not using at all. 

CHAIR BEACH: This is Josie. I would agree with that, Tim, that we 

should discuss it under report 97 when that's available. And other 

subcommittees (sic) thoughts? 
50

MEMBER ZIEMER: Well, I -- this is Ziemer. I agree with that. I'm 

wondering if -- do -- do we need to -- when we recommend closing on this 

one, put in the record, a sentence or two that summarizes what Tim just 

said, as our -- 

CHAIR BEACH: Yes. 

MEMBER ZIEMER: -- basis for closing? 

CHAIR BEACH: Yeah, I agree with -- absolutely agree with that. If --

Kathy, I don't know if, Kathy, if you're capturing these? 

CHAIR BEACH: Yes, I am, Josie. I will -- I will make sure that gets 

into the temporary BRS. 

CHAIR BEACH: Okay. 

(Whereupon, Chair Beach and Member Ziemer speak simultaneously.)

MEMBER ZIEMER: I would favor closing with that addition. 

CHAIR BEACH: Okay, thanks. Other subcommittee members agree? 

MEMBER CASSANO: I agree -- 

MEMBER VALERIO: I agree with that, Josie. 

CHAIR BEACH: Okay. With that -- 

MEMBER VALERIO: Sorry. This is Loretta, I agree. 

CHAIR BEACH: Thanks, Loretta. That just leaves us with 5 and 6 

open at this time, all others are closed; is that correct? 

MR. ANIGSTEIN: Five and six are open. 

CHAIR BEACH: Correct. Yeah, five and six, so we'll -- we'll just move 

-- carry that forward. I don't know how far along NIOSH is on the answer to 

that. Tim, I -- I'm -- I'm assuming you -- did you say November or was that 

for some- -- 
51

DR. TAULBEE: That's correct. 

CHAIR BEACH: -- thing else? 

DR. TAULBEE: November -- 

CHAIR BEACH: November? 

DR. TAULBEE: -- is when we expect to produce our report, and then I 

imagined SC&A is going to want to review it. 

CHAIR BEACH: Yeah. 

DR. TAULBEE: And so, it probably -- we won't be ready to discuss this 

again at the next meeting, I imagine, but perhaps the one after. I'm not 

sure. 

CHAIR BEACH: Yeah, that sounds great. Okay. Any other questions 

on this? TBD-5000? If not, Bob, thank you for your reporting and Tim for 

jumping in when needed. 

And I think we can -- let's go ahead and go with the next one unless 

people are ready for a comfort break now. I was -- my thought was we 

would go through f, and then before we got into the newly issued SC&A 

reviews, we'd take a -- take a break, so. 

MS. MARION-MOSS: Josie, this is Lori. For the record, if we can 

correct that. It's not TBD-5000 -- it is (break in audio) 5000. 

CHAIR BEACH: Oh, so the TBD doesn't belong in there, okay. So, 

Battelle 5000. We'll take that off and correct the record. 

CHAIR BEACH: Appreciate that. All right. Kathy, I think you're up. 

MS. BEHLING: Yes, I am. Can you see my screen? 

CHAIR BEACH: Yes. 
52

OCAS-TIB-009

MS. BEHLING: Okay. All right. This is what we've promised several 

meetings ago, and we're finally getting to it. And just as a reminder, when 

we -- when I initially prepared the list of the subcommittee approved 

documents that were ready to -- to show to the full Board. I lay -- labeled 

several of the documents as not suitable for matrix. And right now, because 

I don't have access to the BRS, I have to go through transcripts to -- to 

make certain decisions. And the reason that I -- I labeled some of these as 

not suitable for matrix is that based on my review of -- of the transcripts, 

there appear to be maybe excessive discussions, maybe involved multiple 

documents, that type of thing. 

So, today's example typifies this type of -- these types of documents 

that fall under this particular category. I would just suggest that as I moved 

through this presentation, I would ask the subcommittee to consider 

whether the approach that I've used seems appropriate. Have I included too 

much detail? I guess, in general, we need to determine what is an adequate 

amount of information that you feel is necessary to share with the full Board. 

So, bear with me as we go through this, and then I'll ask for your opinions at 

the end, or you can ask questions as we go. 

Okay. This -- this particular OTIB is -- that we're going to discuss 

today is the OCAS-OTIB-9. It still has OCAS attached to it because it was 

reviewed back a long time ago. It was -- or it was issued a long time ago, 

back in April of 2004 and the -- TIB is estimation of ingestion intakes. Now, 

this TIB provides guidance on estimating ingestion intakes for unmonitored 

workers. And it includes estimates for both operational and residual periods. 
53

It uses ambient air concentration measurements to estimate in -- daily 

ingestion in the workplace. 

So, SC&A reviewed this TIB-9 back in June of 2006. And back then, 

we -- this is part of one of those sets of procedures that we reviewed. It 

was the second set, I believe. And we actually identified -- I mentioned this 

before, back when we initially started reviewing procedures, we used to have 

a checklist that had review -- observations and review concerns. And they -

- we -- we -- we categorize them as a once -- one through five, and if it got 

anything less than a five, it became a concern or a finding. Back then we 

didn't have a BRS. And so there were several concerns listed in that review. 

However, when the BRS came into existence, they were all -- all those 

concerns were consolidated into one finding that was entered into the BRS. 

And that finding states that the fundamental scientific approach 

reconstruction -- yeah, reconstructing ingestion exposure has flaws that 

could lead to underestimate -- an underestimate of ingestion doses under 

certain circumstances. The subcommittee found that just -- this finding to 

be an overarching issue at one of the meetings, and they actually 

transferred this to -- what NIOSH created was the NIOSH OVER-0002. And 

it was in -- it was titled workplace ingestion.

Okay. After numerous subcommittee meetings and discussions on 

TIB-9, NIOSH issued a white paper, and that was issued on October 23, 

2012, and presented its approach to how they would go about estimating 

ingestion intakes. They did concur that the parameters -- they initially 

concurred that maybe the parameters that we were -- that were listed in TIB 

-- the nine model, they were based on assumptions that -- that have not 
54

been empirically demonstrated to be valid. And if that was found, they 

agreed to revise this approach. 

In reviewing our report, NIOSH characterized this finding in the BRS 

into two general issues. Issue one was the potential lack of an association 

between measured air concentrations in the workplace and surface 

connect -- contamination. And issue two was how do we model the transfer 

of surface contamination to the GI tract through inadvertent ingestion. And 

we just heard Bob Anigstein talk about that in one of his observations. 

Okay. For issue one, SC&A had several concerns regarding surface 

contamination, and they felt assuming contaminants that are 5 microns in 

size particles would likely see a significantly underestimate contamination 

levels. And at rolling -- at uranium rolling mills, airborne part -- particles 

are likely to be a few microns to large, visible particles. And so, the settling 

velocity for these large particles increases dramatically, and there's really no 

limitation for their ingestion. 

We also felt that surface contamination builds up over weeks or 

months or longer, before reach -- reaching equilibrium. And therefore, 

NIOSH at the -- NIOSH's assumption that equilibrium is reached in 24 hours, 

we felt was without a scientific basis, and maybe unconservative (sic). 

And finally, we identified that surface contamination may not be the 

result of settling, but may include things like liquid -- liquid spills, milling, 

grinding, cutting, welding, etc. Sorry. So, to gain a better understanding of 

the relationship between the air -- air and surface contamination levels, 

NIOSH analyzed air and smear samples from both Simonds Saw and 

Bethlehem Steel, uranium rolling operations, and also Superior Steel during 
55

a test -- test rolling and Vitro Manufacturing, and that included 

approximately 240 air samples and 150 contamination smear samples. They 

paired that data and plotted it, and it was determined that the measured 

surface contamination levels were proportional to the air contamination 

levels. 

In doing a linear regression analysis, it showed that surface 

contamination was about 116.7 times higher than the measured air 

concentration. So, for -- now, this slide shows SC&A is concerned regard --

regarding modeling transfer assumptions for surface contamination to GI 

tract in the TIB-9. Assuming a 10 percent transfer of surface contamination, 

to now from -- from one hand appeared unrealistic to us. We felt that in a 

hot, dusty environment, an uninformed radiation worker was likely to wipe 

or contact their face with both hands repeatedly throughout the day. And 

ingestion may involve other modes of intake such as smoking cigarettes, 

direct deposition on -- on the lip.

So, to determine the daily ingestion rates for loose contamination, 

NIOSH used the -- and -- and this is mentioned earlier -- but NIOSH use the 

NC -- NRC computer program RESRAD-BUILD as their ingestion parameter, 

which is based on an extensive review of the literature. This model uses an 

hourly ingestion rate that equals the surface contamination measured in the 

workplace times the effective transfer for ingestion of removable 

contamination. 

And here's what was mentioned earlier, the NUREG CR 5512, volume 

three, assumes the default ingestion transfer rate of 1.1 times 10 to the 

minus 4 square meters per hour. And this actually corresponds to an 
56

ingestion of about 0.5 milligrams per day. Therefore, if we assume an eighthour workday, the obviously, the ingestion rate would be 8.8 E (sic) minus 

4 square meters per day. 

So, the -- the equation on this slide shows that the daily ingestion of 

loose radioactive material equals the NIOSH derived surface contamination 

level of 116.7 times the measured air concentration times the NUREG 

ingestion of 8.8 E (sic) minus four square meters per day. And this results in 

a daily ingestion of 0.103 times 10 times -- times the measured air 

concentration. 

So, NIOSH compared that equation to the ingestion intake equation 

listed in TIB-9, which uses a multiplier of 0.2 to the measured air 

concentration in the workplace. So, based on that comparison, NIOSH 

concluded that using the empirical data and mean value for that NUREG 

default ingestion value of 8.8 minus four square meters per day predicted 

intakes that are about one-half of those used in TIB-9. And NIOSH indicated 

that even though these assumptions are simplistic, it still produced 

estimates of ingestion that are in reasonable agreement with the NUREG 

predictions. So, TIB-9 also includes an ingestion source term for 

contaminated food and beverages. And given the uncertain -- the 

uncertainty inherent in these values, NIOSH felt it's not unreasonable for 

them to continue to use TIB-9. 

In addition, NIOSH pointed out that under TIB-9 -- TIB-9 approach, 

ingestion will always be a fraction of the inhalation exposure. And for 

uranium intakes, the uptake across the gastrointestinal tract is low. The 

ingestion pathway contributes less than 0.6 percent to the dose for soft 
57

tissues under all -- you know, considering all solubility types, and ingestion 

would have the maximum contribution to the GI tract (indiscernible). And 

the highest contribution to a dose is 3.4 percent for the lower large intestine 

when we consider type S solubility is inhale. And in addition, NIOSH applies 

a geometric standard deviation for ingestion of 3 and in some cases, they 

even apply a GSP of 5. 

So, it was just -- it was also discovered by -- that TIB-9 had been 

improperly applied during the residual period as do -- at DuPont Deepwater 

and some other sites. After a -- AEC activities end, it's inappropriate to use 

the resuspension factor to estimate an air concentration and then multiply 

that by 0.2 to calculate the daily ingestion intake. Using this multiplier is 

inappropriate because TIB-9 assumes an active source or process is 

generating the airborne activity. So, if a resuspension factor of 1.1 times 10 

to the minus 6 meters value is used, that would predict an air -- an airborne 

activity that was grossly under represented by the airborne activity that was 

actually depositing the surface contamination. Therefore, NIOSH 

recommended to apply TIB-9 during the residual period, the air 

concentration on the first day of the residual period should be equal to that 

that was present at the end of the operational period. And then we can --

you can apply the TIB-70 source -- source depletion techniques to decrease 

the ingestion intakes over time. So, NIOSH stated that they will review how 

ingestion is being estimated during the residual period at all the sites and 

will issue PERs as necessary.

So, SC&A responded to NIOSH's white paper at the November 1, 

2012, subcommittee meeting. Our first concern was that most of the data 
58

on ingestion from hand to mouth is from studies in the -- in a residual -- I'm 

sorry in a residential setting, which may not represent an industrial 

environment. Also, the data in NUREG CR 5512 and RESRAD came fully 

from Pacific Northwest -- Northwest Lab and represents one set of data. 

And SC&A identified an independent EPA study that looked at the World 

Trade Center workers and used the model for transferring pesticides hand to 

mouth. So, this -- in the EPA study, they found that soft surface ingestion 

rates were about 2.25 centimeters per hour, and this transfer rate agrees 

with NIOSH. However, for hard surfaces, the ingestion rates were 11.25 

centimeters per hour -- centimeters square per hour. 

NIOSH responded to the World Trade Center study through an email 

on January 4, 2013, and indicated that the EPA document was developed to 

identify contaminants of primary health concern to support planned 

residential cleanup efforts. And EPA's methodology was really focused on 

exposures to residents and not qualify -- qualifying exposures to cleanup 

workers. And therefore, NIOSH felt that their ingestion parameters that 

were developed in RESRAD are still the best available set of data for 

estimating ingestion exposure. 

So, we closed -- we closed finding one by -- SC&A considered that the 

difference between the World Trade Center study and the TIB-9 and the 

uncertainties involved, that the agree -- the agreement between the hand 

and mouth was reasonable. SC&A also noted that the difference in the 

hand-to-mouth ingestion model between workers and residents has more to 

do with the exposure duration than the transfer rates. So, SC&A did 

recommend closure, and at the February 5, 2013, meeting, the 
59

subcommittee closed TIB-9 over -- overarching -- overarching two finding 

one. 

So, this shows, as I said, an example of -- of one situation where this 

did not fit the typical matrix. And we had about, what, 16 slides to present 

one finding. I will also make mention that in preparing this presentation, I 

decided to revisit all of the, quote, not suitable for matrix documents. And I 

guess, in going back now that we've moved forward so much, probably a lot 

of them could be put into more of a matrix style than this particular one. 

And so, they may be a little bit more complex, but I still think they would --

would fit into that matrix approach -- approach. 

The only other thing I'm going to say is for a lot of these, I 

unfortunately, will need to request Lori's -- Lori Marion-Moss's assistance to 

provide the BRS entries because that -- perhaps if I would have had that 

data from the BRS when I compiled this list, some of these documents would 

not have maybe fallen under this not suitable for matrix. So, as we move 

on, I hope that I can perhaps rely on Lori to -- to help me focus my 

presentation and get something into more of a matrix style approach. 

So, I guess, the question is, is this too much data to present to the full 

Board? What are your thoughts as to how we move forward?

CHAIR BEACH: Thanks, Kathy. One thing I'll say is, it is a lot of 

information; however, I know going back over the last several years and 

several discussions, it's important -- important that the Board understands 

why we got to where we got. One of the things I was thinking as you 

started this was, we -- when we present this to the full Board, I think we 

need a preamble slide or just a discussion of what you're doing so it's 
60

understood. I mean, we've gone through a lot of the ones on the matrix 

that we've closed out, but it needs to be understood that you are presenting 

information that has been closed out by the subcommittee; we're just 

reviewing for the full Board the facts. I just think it's important to -- to give 

that little talk ahead of time. Other -- 

MS. BEHLING: Okay. 

CHAIR BEACH: -- subcommittee members? 

MEMBER ZIEMER: Well, I guess the -- 

MEMBER VALERIO: This -- 

MEMBER ZIEMER: real quest -- there's two parts to the question. One 

is what you put in the records of the matrix, I guess, the other is what you 

present to the Board. I think, Kathy, when we realize this is just one 

finding, and really the labyrinth of information we had to go through to -- to 

close this out, to me, it is almost too much information for the Board of -- I -

- I'm -- what I would struggle with is to find a suitable amount that's suff --

is adequate for the Board's decision with the opportunity for individual 

members to explore in more detail if they wished. And the same would be 

on the matrix. I think in the matrix, sometimes what we've done in the past 

is -- is have something that you could click on in the matrix to open up 

details on a particular finding where it's a solution. But I -- I'm struggling a 

little bit to think if we had a presentation where we have multiple findings 

just for one sight, this is just a -- becomes an expansive amount of detail for 

the Board, for the full Board in my mind. 

MS. BEHLING: Okay. In this particular case, it just so happens that 

the NIOSH white paper was posted on the website, and so that is something 
61

that we could -- we could link to, and so we could reduce a lot of the 

discussion on -- on that topic, because they could refer to that white paper. 

So, that's an option in this particular case.

CHAIR BEACH: I think that's a good suggestion. And Loretta, and I 

think you were trying to make a comment earlier? 

MEMBER VALERIO: I was. I wanted to thank Kathy for the 

information. Being fairly new to this workgroup, this gives me some -- you 

know, back when all this started, I wasn't even on the Board. So, the 

detailing, it helps me understand better the process and what has happened 

over several years, as you mentioned. But on the other hand, I also agree 

with Paul that, you know, when it comes to the Board, if there's a situation 

where we were reviewing different -- for several findings, it could be very --

I want to use the word cumbersome, but it can be a lot to have to read 

through. So, having the white paper and knowing the history and so -- I'm 

kind of on the fence on this, because I -- I appreciate the information that's 

given to us, but when you're in a board meeting, that's a lot of information 

to relate to the entire Board. Does that make sense? 

CHAIR BEACH: Yes, that does make sense. 

MEMBER VALERIO: But I do appreciate Kathy's work on this. 

CHAIR BEACH: Yes. 

MEMBER ZIEMER: And one -- one thing again, let me -- this is Paul 

again. It's not unlike the other -- the subcommittee on dose reconstruction. 

They -- they have to summarize what they have done as a subcommittee, 

but we -- they -- we -- we can’t rehash everything that they did in detail. I 

think that's the reason we have workgroups and subcommittees to do a lot 
62

of the detailed work, and we're dependent on each other to do that in a way 

that -- you know, we rely on each other to say yes, they have looked at this 

in detail and that they are summarizing what they did, and if -- if I want to 

see all that detail, I have the opportunity to, but otherwise, I will rely on 

their recommendations. And so yeah, well, I'll leave it at that. 

CHAIR BEACH: Yeah, Paul, I agree with that. So -- so, Kathy, I think 

what you're getting is that too much information, potentially, and if we could 

link other files so that if somebody is curious can walk down that lane, so to 

speak, and then maybe shorten it a bit. 

MS. BEHLING: I agree. That's why I decided to put a lot of detail into 

this one to get your opinion. 

CHAIR BEACH: Yeah. And Victoria, what do you think? As a new 

subcommittee member, what did you think? 

MEMBER CASSANO: I -- I am a little conflicted, but I think that a 

synopsis of what was presented here with the link to the -- the document on 

the website would be fine for the full Board. I mean, I appreciate the indepth analysis and it did help me understand a lot of what went into this 

whole determination, but I -- I think that considering that this is going to be 

a one-day meeting in August, if we were going to present this in August, 

that there's probably TMI, it's probably too much information. And I think a 

lot of people would struggle to follow it, like I did in this meeting, even 

though I pre-read this. I think it's too much information. 

MEMBER ZIEMER: On this particular one -- 

MS. BEHLING: How do you -- 

MEMBER ZIEMER: -- wouldn't be -- 
63

MS. BEHLING: Huh? 

MEMBER ZIEMER: This is just an example, right? You're not 

presenting this at the meeting, or -- I assume, or is this on the agenda? 

CHAIR BEACH: No. We haven't come up with the agenda. That's 

subject to discussion later on in this meeting of -- of what we want to do to 

present. I think our time is shortened at the upcoming August meeting, so it 

-- we'll -- 

DR. ROBERTS: Actually, -- 

CHAIR BEACH: -- we'll discuss what -- 

DR. ROBERTS: -- (indiscernible) -- 

CHAIR BEACH: Oh, go ahead, Rashaun. 

DR. ROBERTS: Sorry, Josie. But no, you had -- I think you requested 

the 90-minute slot, and so -- 

CHAIR BEACH: Okay. I wasn't -- 

DR. ROBERTS: -- (indiscernible) -- 

CHAIR BEACH: Yeah, Rashaun. I wasn't sure if that was going to be 

reduced to an hour or not, so. 

DR. ROBERTS: Right, right. But it -- right now, it's 90 minutes. 

CHAIR BEACH: It's still 90. Okay. All right. So, I think we'll talk 

about that on item three before we close out today. So, this is potentially 

one that could be presented, but maybe in a shorter version, correct, Kathy? 

MS. BEHLING: Correct. In fact, that would be beneficial for me since, 

you know, we're coming up quickly on the August meeting. And what I can 

do is -- which I -- I always do get your approval, but I'll pare this down, and 

maybe we can -- if we have 90 minutes we can, at the end of this meeting, 
64

add a few other approved documents. And then I can have you all approve 

that before we send it off to the full Board. 

CHAIR BEACH: Okay. 

MS. BEHLING: I understand now. I have a better understanding. I 

agree. And I think Paul had mentioned even at one of the full-Board 

meetings, is it really the Board's job to reassess all of these issues or do 

they take the advice of their subcommittees and work groups and assume 

that they have thoroughly reviewed all these issues and -- and come to 

certain conclusions for certain reasons. And so, I -- I agree with paring this 

down, but I, like I said, did include this level of detail just so that we could 

make a decision on that. 

CHAIR BEACH: Okay. Yeah, and I think in this case, the trail that 

what we've done is important and maybe not the finer details. Just to note 

that we had looked into this extensively and those as -- the subcommittee 

came to the conclusion of closure and we're looking for agreement, not 

rehashing. So, I agree with that. Okay. Any other comments on this before 

we move on? 

I'm gonna say we should take a break, Rashaun and other committee 

members, that is 15 minutes adequate or would you like more time, lunch 

break, time? I know I ask this every subcommittee meeting. Is it okay -- 

MEMBER VALERIO: (Indiscernible) I'm good with 15 minutes. 

CHAIR BEACH: Okay. 

MEMBER CASSANO: Fifteen minutes is fine. 

CHAIR BEACH: Okay. Let's -- 

MEMBER ZIEMER: I can do 15 minutes. That's good. 
65

CHAIR BEACH: All right. So, let's take a break until, my time, 

10:30, -- 

MEMBER ZIEMER: Okay. 

CHAIR BEACH: -- 1:30 Eastern. 

DR. ROBERTS: Eastern, great. 

CHAIR BEACH: So, we'll take a 15-minute break -- 16 actually, thank 

you. 

MEMBER ZIEMER: Very good. 

NEWLY-ISSUED SC&A REVIEWS

DR. ROBERTS: I do have 1:30 p.m. Eastern time. I'm going to take a 

quick roll call. Hopefully everyone's back. Okay, starting with Beach. 

CHAIR BEACH: I'm here. 

DR. ROBERTS: Cassano? 

MEMBER CASSANO: I'm here. 

DR. ROBERTS: Valerio?

MEMBER VALERIO: I'm here. 

DR. ROBERTS: And Ziemer? 

MEMBER ZIEMER: Here. 

DR. ROBERTS: Okay, great. Josie, over to you. 

CHAIR BEACH: Okay, thank you. I see that the white paper for 

ORAUT-OTIB-0087 is up. I think we probably need to start with the slides 

though. And Ron, are you pre -- ready for that? 

DR. BUCHANAN: Yes, I'm ready. Kathy, can you present the slides? 

MS. BEHLING: Yes. I -- 
66

CHAIR BEACH: Okay. And you are ready? 

MS. BEHLING: -- apologize. Can you -- 

CHAIR BEACH: -- ready, thank you. 

MS. BEHLING: -- see -- 

CHAIR BEACH: Yes, we can see that, -- 

DR. BUCHANAN: Yes, we can -- 

CHAIR BEACH: -- thanks, Kathy. 

MS. BEHLING: Okay. 

OTIB-87

DR. BUCHANAN: Okay, so if you're ready, this is Ron Buchanan with 

SC&A, and I'll be presenting our review of OTIB-87, which is concerned with 

extremity doses for the Mound exposure to Plutonium-238. And I'd like to 

acknowledge my coworker, Richard Griffiths, for his contribution to the 

statistical analysis in this reporting.

Now, the progress of this OTIB-87 was issued by NIOSH in 2017. It 

provides information to use to determine the ratios to assist in assigning 

extremity dose. And some employees at Mound were only issued wholebody dosimetry; however, when they worked or handled Plutonium-238, 

there's a chance that they was exposed to higher doses to their extremities, 

which includes the forearm, wrist, hands, and fingers in compared to the 

whole-body dose. And if ED -- extremity doses -- results are available, of 

course, they'll use those. Some of them were monitored on their extremities 

but some were not. If not, then this OTIB provides ratios to apply these 

whole-body dosimeter, which most everybody would have if they was 

working around plutonium, but they might not all have extremity doses and 
67

so -- dosimeters. And so, this OTIB covers it, that area.

Next slide. Okay. So, (indiscernible) was in October of 2022, the SPR 

tasked SC&A with a review of OTIB-87, and we performed that review and 

issued an uncleared version in April of '23 and then we issued a cleared 

version in May of '23. 

Now, use the data for this OTIB came from a Mound 1972 extremity 

dose study, which monitored personnel working with the PU-238 operations. 

PU-30 -- 238 is usually used as a heat source so it inquires -- it requires that 

encapsulation and handling, milling, and that sort of thing. And so, they 

handle these things in glove boxes usually, and so the hands can get greater 

dose than whole body would register. And so, the -- the wrist badges were 

used for determining gamma exposure using TLDs and neutrons, of course, 

at that time, they used the NPA film. And the work was performed in, like I 

say, such as glove boxes around PU-238 and the -- for various lengths of 

time reading -- ranging from a couple of weeks to up to 22 weeks, and the 

dosimeters was changed out two weeks. 

Okay. Now, there was two studies, the one I just talked about with 

the wrist to the whole body, and then we had one that was '72 and '73 also 

at Mound, performed by the same method, same people, and this 

determined the -- the people working in glove boxes wearing lead-lined 

rubber gloves and used the gamma and neutron dosimetry methods as they 

did in the previous study. Now, however, for the fingertips, they could only 

do the gamma measurements because they used TODs on the fingertips to 

determine the dose of the fingertips, and they range from three to 10 days 

of exposure during dosimetry change out. 
68

Next slide. Now, NIOSH used these -- this data from these two studies 

to determine the ratio of the left wrist to whole body and the right wrist to 

whole body gamma and neutron exposure, and also the left finger to the left 

wrist and the right finger to the right wrist gamma ratios. Like I say, the 

NPA film wouldn't work on the fingertips, but they did use TLDs for gammas, 

and that was limited to a few applications.

Next slide. Okay. This data that NIOSH analyzed and has in OTIB-87 

is summarized in Table 5-1, which summarizes the wrist-to-whole body 

dosimetry for both lest -- left and right wrist compared to the whole body for

28 employees handling PU-238 at Mound different operations, there's nine 

different operations that are categorized. And they found that this ratio for 

gamma dosimetry was best represented by a Weibull distribution and figure 

5-1 OTIB-87 presents a summary plot of that distribution comparing the 

gamma wrist-to-whole body ratio. NIOSH decided -- determined that the 

Weibull distribution with a value 1.3, (indiscernible) 1.9, and a location of 

.34, best fit the data.

Next slide. Okay. Then we had the neutron dosimetry in Table 5-1 

again, summarizes neutron wrist-to-whole body for dosimetry points for 28 

employees for nine different operations, and NIOSH found that the wrist-towhole body dosimetry was best represented using a lognormal distribution 

and figure 2 of OTIB-87 provides a plot of that data. And NIOSH determined 

that lognormal distribution with a (indiscernible) metric mean of 1.5 and a 

standard (indiscernible) 2.5 was most appropriate for this data. So, now that 

was the wrist-to-whole body, now the second study was wrist to finger -- or 

excuse me, finger to wrist gamma dosimetry data analysis and Table 5-2 of 
69

OTIB-87 summarizes that data both the left and right hand for six workers 

for three different operations. Less workers and less operations did the 

fingertip study. And NIOSH found that because there was limited data that 

a fit comparison couldn't be determined, therefore, they recommend using a 

normal distribution (indiscernible). And for this limited the data set, NIOSH 

did calculate average ratios of left hand -- finger to the wrist of 3.18 with a 

center deviation of .5 and a right finger to wrist ratio of 2.76 with a deviation 

of .85. And so, they recommend that unless it's known if they're right- or 

left-handed to use the most conservative ratio of 3.8.

Next slide. Okay. So, now, this was NIOSH's analysis of the data and 

as they used it in OTIB-87 that I just reviewed. Now, we're looking --

SC&A's review of OTIB-87. And to do this, we evaluated the original 

recorded Mound data. We went back to the (indiscernible) looked up the 

original data and compared it to NIOSH's use of the data. And they used the 

data in five -- in Table 5-1, 5-2, and figure 5-1 and 5-2 of 87. We also look 

at their recommended dose reconstruction recommendations in Section 6 of 

OTIB-87. So, we also performed a statistical analysis of the data used in 

OTIB-87, and we have that in our attachment to our main report we issued 

in May. 

Next slide. So, evaluation of the original Mound data, SC&A reviewed 

the data provided by Mound, and we found that the measurements were 

conducted using acceptable dosimetry methods. However, we did find that 

the quantity of data was somewhat limited, only had data from 28 

employees where the wrist-to-whole body ratios and only data from six 

employees for the finger-to-wrist ratios. And we also see large variations in 
70

resulting ratios from .3 to 7. In other words, you would multiply the wholebody dose by .3 up to point -- all the way up to 7 to determine the wrist 

ratios, as we see in Table 5-1, for both the gamma and neutron ratio values 

range between .3 and 7. 

Next slide. And then there also was a variation assumption operation, 

like I say, there was nine different operations. We reviewed the wrist-towhole body ratios to determine if there's a correlation between the ratio 

values to the operation or if it's just random values throughout the nine 

different operations. And we find that the wrist to left -- right and left wristto-whole body ratios varied (indiscernible) with a fiber operation for both 

gamma and neutron doses. And we summarized those in Table 1 in 2 of our 

recent report and looked at the descending ratios as a function of operation, 

and you can look at that table if you'd like more details on that. And we also 

examined more details on nasty and attachment A of our recent report. 

Next slide. Okay. So, some of the analysis of the original data 

NIOSH's use of it in OTIB-87, we find that -- finding one, that when applying 

the ratios to other operating periods, even at Mound or other DOE sites, 

NIOSH would use -- have an understanding that exposure conditions are 

similar to those used in 87. Realize these were, you know, for a limited 

amount of time, you know, several months at a certain facility and a certain 

location. So, considering the variations in the wrist-to-whole body ratio 

values as a function of operation, especially it is important to apply the 

Mound extremity ratio values to ERs from other operating periods or other 

DOE sites to first -- certain that the condition of exposure of the Plutonium238 are encompassed by the Mound operations. In other words, if 
71

somebody's not working and under similar conditions, he could have a lower 

ratio, which you'd be conservative to apply the Mound ratios, but they could 

have a higher ratio too, which would underestimate their assigned dose at a 

different facility or a different time, even at Mound.

Next slide. So, now we did evaluate Table 5-1 and 5-2, and we came 

up with several observations. In that -- observation one, we have found a 2 

increase from the Mound data not included in OTIB-87. We found that 

NIOSH included all six entries of the Mound data for the finger to wrist whole 

body exposure in Table 5-2. So, Table 5-2 has all the data available for the 

finger information; however, it -- it appeared that we could not find the --

the fifth and sixth data entry. We found the first four that was used in 5-2 

in 5-1, but we didn't find the last two. And this omission of using those two 

would not greatly affect the results, however, it would be useful to know if 

there was a reason that NIOSH did not use the last few entries that was 

used in Table 5-2 why they were not used in 5-1. 

Next slide. Okay. So, then that was evaluation of Table 5-1 and 5-2, 

and then we have Figure 5-1 and 5-2. That leads us to our second 

observation in that when we counted the details of the number of ratio 

values in Figure 5-1, we find that it states there's 55 when they created the 

Weibull distribution curve; however, we only counted 45 valid wrist-to-whole 

body gamma ratios as reported in Table 5-1. And also see that the figure in 

5-1 says there's a mean ratio of 2.116 with the mean ratio -- if you calculate 

it in Title 5-1, it's 2.143. And then we have a similar thing for neutrons in 

the Table -- Figure 5-2 reports 53 values and -- or as there's only really 43 

valid wrist-to-whole body neutron ratios in Table 5-1. And we see that 
72

Figure 5-2 also lists the minimum and mean neutron ratio as .179 and 2.551 

respectively, while those -- if you do the calculation in Table 5-1 it's .27 

mean and -- let's see the -- the wrist-to-neutron ratio in Table 5-1 is .27 and 

the ratio is 2.502. So, we -- you know, it’s not a big issue, but there are 

some discrepancy between the figures in tables in OTIB-87.

Next slide. Okay. We have -- like I say, we did statistical analysis of 

the raw data itself and we found that in the summary the attachment to our 

report is quite detailed that Richard Griffiths devised and wrote up; however, 

I'll just summarize it here. Is it the start -- the data is sparse, and it varies 

in -- in Table 5-1, so we suggest that the estimated ratios in OTIB-87 are 

likely quite imprecise and there're several issues that suggest this. The 

sparsity of data, relatively few number of operations, outliers, there're some 

large outliers in the ratio measurements affecting the fit, and then linear 

relationship was assumed, however, there might not be a linear relationship 

which wrist dose and whole-body dose for all the different operations. And 

the operational types indicate there is a relation share between the ratios for 

different operations. In other words, some operations might have a different 

ratio or categories of ratios than the others, which suggests the need for a 

different estimation methods for the different type of operations for it to be 

valid. However, we do have a solution to that problem.

Next slide. We have the results of our analysis and it's Attachment A 

to our report. And from that attachment, we find finding two, which is a 

suggestion by SC&A that considering the limitations of the data, that it might 

be more appropriate and claimant favorable to use a rounding ratio, such as 

other -- upper limit of confidence interval instead of a distribution or average 
73

ratio value. Since the data is pretty limited and you probably -- not a whole 

lot of DRs are done with this, the use of an upper limit -- reasonable upper 

limit applied would make sure that it encompassed the dose and bound the 

dose. Next slide. NIOSH did recommend in section six of the OTIB to 

determine the gamma to wrist using the Weibull distribution for gamma and 

the lognormal for the neutron and the finger-to-wrist extremity doses to use 

3.18 for the left, 2.76 for the right, and if it's unknown, use a conservative 

3.18, so that's a recap of what they recommend. 

Next slide. And so, we conclude from our evaluation that the original 

recorded Mound data used to construct Table 5-1 and 5-2 and the DR 

recommendations are reasonable, however, we present -- performed our 

own statistical analysis of the recorded data, and we identified two findings 

and two observations as I just discussed. Finding one is that -- cautions 

when applying the ratios to other operating periods or DOE sites. Now, we 

bring this up because we did have dose reconstruction -- Pantex Plant, 

which -- that used this method and we've seen no justification in the DR 

report anyway why this could be applied from Mound in the '70s to the 

Pantex case whenever this worker was exposed. And so, it perhaps can be 

used, but there needs to be some due diligence in assuring that the ratios 

are applicable. 

In finding two, in the long run, we think that the -- it's uncertain as to 

all these ratios are, it could be more appropriate to use an upper bounding 

for dose reconstruction. And observation one was concerned with the --

where the data was not entering in the Table 1 -- Table 5-1 where it did 

appear in Table 5-2. And observation two was some discrepancy in the 
74

number of ratios and values as what's listed in Table 5-1 as compared to 

what actually appears and Table 5-1 and 5-2. 

So, I think that's my presentation. Open for discussion. 

CHAIR BEACH: Thanks, Ron. I appreciate that. I was surprised when 

I read this that there was such limited data. I would think there would have 

been a lot more of the finger rings used therefore having more data for this 

though. It's not really a question, just -- I was curious about that. 

DR. BUCHANAN: Yeah, it shows a limited application. There's not 

been too much work done that I -- you know, I've worked a lot of sites, and 

I don't recall a lot of sites so addressing this issue. 

CHAIR BEACH: Right, thanks. Other subcommittee members, 

questions for Ron? 

MEMBER CASSANO: I do have a question about using what -- the 

upper bound of the confidence interval. I would presume that in looking at 

these, because you have such limited data, that the confidence interval must 

be rather broad, and especially if the outliers are included in that evaluation. 

I'm just wondering -- while I -- I see how it is much more employee 

beneficial, might use not be actually way overestimating exposure? 

DR. BUCHANAN: Yes, you could. But in the past, we've always erred 

--we'd rather -- we'd rather overestimate than underestimate. Perhaps, you 

know, statisticians can address this, but if you remove some obvious outliers 

and you come -- you can -- you could come up with a reasonable upper 

bound, not necessarily extreme. But I would say, you know, if that was 

developed, then you'd have to address obvious outliers and come up with a 

reasonable upper bound. 
75

MR. GRIFFITHS: Hi, yeah. This is Richard Griffiths. So, I'll try to 

address this a little bit too. I think, you know, the concern is, obviously, 

that there's so little data and there's -- you know, we see so much variation 

in the ratios that were used in, you know, that were observed, that using 

something like just an average or some the -- even the parameters, even 

putting in empirical distribution, like's done in this paper, that the 

parameters even from those are -- are really unstable. So, clearly if we 

would've used the --you know, used something like just an estimated 

average, and these are estimates, we might be, you know, very much 

underestimating truth of an actual -- the actual ratio that's in population. 

So, you know, we haven't -- we didn't specify exact what the upper bound 

would be, but it since it would -- it's -- you know, it could be very client 

unfavorable to actually use an estimate that just because of a particular 

sample of data that we had is, you know, affected greatly and is rather small 

in comparison to an -- you know, the actual ratio that's in the population. 

So, it's just -- it's -- you know, yes, the confidence interval would 

probably be really large, and I think that's -- I think that's, you know, 

something to point out here too we don't even know what the confidence 

interval would be. We don't know what the standard errors are on these 

estimates. And I think -- I think it would go a long way to answering some 

of the questions, you know, about what this would actually look like in 

practice if we -- if -- if that were addressed with the actual, you know, 

uncertainty and precision of these -- these numbers were. But I -- yeah, I 

think, you know, the reason for recommending using an upper bound is 

basically that using an average value subject to such uncertainty could be 
76

very much client unfavorable. 

MEMBER CASSANO: Yeah, no, I understand that. It sounds like given 

the (indiscernible) of the date, you're sort of in between a rock and a hard 

place. And I would agree that it is much better to do err on the side of the --

the employee than -- or the claimant than not to. So, thank you for the 

explanation. 

MEMBER ZIEMER: Yeah, this is -- this is Paul Ziemer. I might add to 

that, that follows the usual practice of taking the distribution, which in many 

cases lognormal. The Weibull distribution sort of looks like a normal --

lognormal anyway, but going toward the upper tail of that to assure that you 

are, in a sense, bounding what could be. I'm -- I'm looking right now at 

Figure 1 of the actual report. I don't think you showed this slide on -- on 

the slide reason presentation, but I'm looking at the -- the wrist-to -- towhole body doses for a -- I guess it's twenty -- it goes 1 to 28. I guess each 

of those is a person, right? And -- and the range on those is everywhere 

from close to 1 to up to 7 times, so it's really a very broad range of 

parameters that -- with only 28 people. It's a big spread. So, you have the 

-- you have the possibility that the -- the actual numbers could be up toward 

7, even though there's not many that are up that high on the ratios. 

CHAIR BEACH: Paul, I think you stumped everyone -- 

MEMBER CASSANO: (Indiscernible) as an issue. I understand the -- I 

understand the difficulty in doing it, and I would concur that better to err on 

the side of the -- of the claimant than not. So, but I just wanted to mention 

that as a possibility. Thank you. 

CHAIR BEACH: Thanks, good discussion. NIOSH any comments, 
77

or...? 

MR. RUTHERFORD: Yeah, Josie, this is LaVon. Tim and Lori are both 

conflicted on this, so I will say we are developing responses to the findings 

and observations, and I don't think we have a good date for when we'll have 

that, but we are working on those. 

CHAIR BEACH: Okay. That's pretty much what I thought, so we --

any other questions or comments? If not, we can move on to the next 

presentation. Okay. Thank you, Ron. And I think we're ready to move on, 

and we will carry this over. 

MS. BEHLING: Okay. Josie, this is Kathy. Are you seeing my slide --

my slides? 

CHAIR BEACH: Yes, we sure are. 

MS. BEHLING: Okay. So, if you're ready, I'll start with report 85. 

RPRT-0085

MS. BEHLING: This is our review of ORAUT report 85 and that is 

probability of causation valuation for ICRP 116 anterior-posterior, isotropic, 

and rotational geometries. Now I'll start off by saying that I'm making this 

presentation, however, Ron Buchanan and Doug Farver did most of the 

heavy lifting, like John Maher (ph) would say when -- and they performed all 

the -- all the calculations, and I peer reviewed everything and wrote the 

report, but it was certainly a team effort here. 

Okay. We need to go back on this discussion to -- back to 2005. I 

think IG-001 was one of the very first documents that SC&A reviewed. And 

IG-001 is our external dose reconstruction implementation guide. In that 

review, SC&A determined that when applying rotational and ISO and DCFs, 
78

it could lead to an underestimate of the external dose. Thereafter, NIOSH 

had recommended to the dose reconstructors that they only use the A-P 

geometry. However, NIOSH recognized that for certain cancers, specifically, 

bone, red marrow, and surface, the esophagus, and the lung, the A-P 

geometry for the dose -- the dosimeter worn on the chest was not the most 

claimant favorable. So, they developed correction factors for the rotational 

and isotropic geometries, DCFs for these organs. 

Now, NIOSH are currently in the process of replacing the IG-001 DCF 

values with the ICR -- ICRP publication 116 dose conversion coefficients. 

And this is what prompted the issuance of report 85. NIOSH wanted to 

determine if the -- the rotational and isotropic DCFs that they had developed 

that are listed in IG-001 are still valid. So, to assess the most claimant 

favorable exposure geometries, NIOSH derived a POC and a dose for all of 

the ICRP 116 organs, and they have a table in report 85 that lists 33 

different IREP models. They did this for male and female, and they assessed 

for neutrons. They assessed 32 neutron energies and 20 photon energies. 

And also, they looked at exposures from three exposure geometries, the AP, rotational, and isotropic. They calculated doses for personal deep dose 

equivalent, the HP-10, and also exposure dose, and they assessed this for 

dosimeters that were located at four different locations that would be placed 

in different locations on the worker's body; the center chest, left collar, the 

center waist, and the left chest pocket. So, for their POC calculations, doses 

-- they calculated doses using irradiation geometry factors that were 

previously developed in their report 86. And report 86's correction factors 

for use with ICRP publication 116, isotropic and rotational dose conversion 
79

coefficients. 

They assumed -- for IREP, they assumed a five-year work period for 

the individual starting at page -- eight -- 35 and had a latency period of 

three years for leukemia, seven years for the thyroid, and 10 years for all 

other cancers. They applied a dose of 2 rem per year, and that was entered 

into IREP as a log -- as a normal distribution with a 30 percent uncertainty. 

I'm sorry, I forgot to change that slide. There you go.

They also do -- did a dose-only calculation. And in this calculation, 

they assumed 500 millirem of measured dose and 500 millirem of missed 

dose. The measured dose was assumed to be a normal distribution with 30 

percent error, and the missed dose was assumed to be a lognormal 

distribution with a GFC of 1.52. Doses were combined with the ICRP 116 

dosimeter -- yeah, DCC, dosimeter coeff -- co -- yeah, DCCs, and the report 

68 IGF values for the four dosimeter locations. And they used the Monte 

Carlo method to come up with these doses. NIOSH also utilized the DCC 

distribution data developed in -- in a report that they had previously 

published, and that's report 69, which is updated ICRP 116 dose conversion 

factors and comparison to ICRP 74 dose conversion factors. 

So, as a result of the POCs and the doses that were generated in 

report 85, NIOSH could not identify any concise geometry determinations as 

were listed in Table 4.1A of IG -- of IG-001. I -- I -- I will just make a --

stop here for just a second because IG-001 has two tables listed as table 

one -- Table 4.1A. We had pointed that out to NIOSH many years ago, and 

they just -- it hasn't been changed. The table we're talking about is on page 

39. I'll just make mention of that in case you actually go in to try to look at 
80

that table. 

They found that --- what they did find is for most radiation typed 

organs and dosimeter locations, the AP and the rotational geometry is 

delivered the largest POC. Exceptions included the female adrenals where 

the ISO was more predominant for photons and, with few exceptions, the 

dose-only results were in close agreement with the POC results.

So, SC&A evaluated NIOSH's technical approach and report 85 

documentation for assessing the most claimant-favorable geometry. NIOSH 

did rely on data from reports, as I mentioned, 86 and 68 and 69. And I just 

want to make mention, SC&A has not previously been tasked to review 

these two reports, therefore, our assessment of 85 just uses that data 

without verifying their accuracy.

Okay. So, first SC&A compared report 85 Table 2.1. And this table 

lists the IREP models that NIOSH used for all of the ICRP 116 organs and 

tissues. And we compare that to OTIB-5, which is the internal dosimetry 

organ, external dosimetry organ, and IREP model selections by ICD 9 code, 

that was rev. 5. I know it has changed to rev. 6, and we're using ICD 10, 

but as part of report 85, they still use rev. 5. And SC&A agreed with NIOSH 

-- NIOSH's selection of IREP models. There was the muscle that was listed 

there that's not in OTIB-5, but they used connective tissue, which is 

appropriate. For calculating POC doses, SC&A first had to derive the IGF 

using -- we didn't use Monte Carlo methods, so we use an arithmetic mean 

value of the IGFs that were listed in report 85. And then rather than 

calculating the IGFs for all of the energy ranges that were assessed by 

NIOSH, we just focused on those that are typically used in dose 
81

reconstruction, and those included the photon energies of less than 30 keV, 

30 to 250 keV, and a greater than 250 keV. And for neutrons, we looked at 

neutron energy ranges of less than 10 keV, 10 to 100 keV, 100 keV to 2 

MeV and 2 to 20 MeV. 

And since the report 85 IGFs were derived from report 68, we 

compared our values, our arithmetic mean values, to report 68. We found 

that there was reasonable agreement between the report 85 and the report 

68 energy values; however, we did identify some deviations in several of the 

report 85 rotational and isotropic neutron IGFs. 

And that -- I'm sorry -- that became our observation one. I apologize 

for not changing the slide again.

Okay. All right. Observation one. SC&A questions why NIOSH --

NIOSH's neutron IGF for several dosimeter locations differ from those in 

report 68. Using report 85 IGF values, SC&A's mean female and male IGF 

values for several of the neutron rotational and isotropic dosimeter 

placements were generally about 20 to 25 less than those reported in report 

68. There was only one exception where SC&A's value was about 24 percent 

higher. That was the rotational centered -- center chest for less than 10 

keV. All the others were -- all the others were lower values, and they --

they focused in on the neutron values -- neutron ranges of 2 to 20 MeV. 

So, this led SC&A to question why NIOSH's report 85 IGF values 

differed from those of report 86, and they stated that that was the -- report 

86 is the basis for -- for developing or listing their IGFs in report 85.

Okay. Hold on one second. Just a second. So, SC&A, considering the 

-- the vast number of iterations that were assessed by NIOSH, for this 
82

evaluation, we just -- we determined that it was appropriate to only look at 

a subset of the data. So, we looked at just a subset of the photon and 

neutron energy ranges. We looked at only two dosimeter locations, and we 

looked at only eight cancers. For the energy ranges, we looked at just the 

photons that are 30 to 250 keV, and for neutrons we evaluated the 0.1 to 2 

MeV, MeV neutrons. We also only evaluated two of the four dosimeter 

locations and those that we considered were the -- the most prominent or 

that we would expect for the EEs under this program was the left chest 

pocket and the left collar, and so those were considered in our assessments. 

And we looked at eight female and eight male cancers, and that was the 

lung, the esophagus, the red bone marrow, the adrenals, bladder, breast, 

sinus, and prostate for the male and ovaries for the female.

So, SC&A's method for assessing the DCF values, NIOSH derived DCF 

values using Monte Carlo techniques and data from ICRP 116 as well as 

report 69. So, SC&A derived DCF by calculating the mean value of DCF listed 

in report 69. This -- the review of 85 did require SC&A to become familiar 

with data contained in ICRP 116 and report 69, so I'm going to give you an 

overview of that. The reason my -- okay. My -- I -- I'm -- I'm confused by 

some of my slides here.

This slide presents an over -- presents an overview of the pertinent 

data in ICRP 116. ICRP 116 lists values picograys, which are absorbed dose 

per unit fluence. These values are called dose conversion coefficients and 

these DCCs are listed for male and female organs for A-P, rotational, and 

isotropic exposure geometries. The DCCs are listed for 55 photons energies 

between 0.01 and 10 MeVs and 68 neutron energies between 1E-9 to 10,000 
83

MeV. 

And okay. An overview of report 69. This report derived DCF values 

by applying neutron and photon fluence conversion factors to the ICRP 116 

values. It lists photon and neutron organ DCF, organ A-P, P-A, rotational, 

and isotropic geometries for all of the ICRP 116 cancers. And photon DCFs 

are separated into 20 energies between 0.01 MeVs to 3 MeV, and neutrons 

are DCFs are divided into 33 energies between 1E-9 through 2MeV. 

So, SC&A's approach to deriving DCF values, first, report 69 provides 

an example equation showing how they calculated photon and neutron DCF 

values. And we did evaluate that -- those equations, and we found them to 

be appropriate. We did take issue with some of the terminology used in 

those, but that we will discuss in a later observation. So, since report 69 is 

photon DCF values for 0.2 MeV and 0.3, to derive -- SC&A averaged those 

two values together to come up with our 250 keV photon energy DCF. To 

derive the range of DCF values for photons, which is 30 to 250 keV, we used 

the eight DCF values that were reported in report 69, plus that arithmetic --

arithmetic mean value between 0.2 and 0.3. 

The main neutron DCF value for SC&A, we calculated that using the 

ten DCF values that were listed within the range of 0.1 to 2 MeV in report 

69. We calculated DCF values for the 8 female and the 8 male SC&Aselected organs. For calculating POC values, SC&A used our derived IGF 

values for the left center pocket and the left collar, and also, we did that for 

the A-P, ISO, and rotational geometry. We calculate -- we -- we came up 

with DCF values for those three geometries. 

And then using report 85 assumptions, we generated POC values 
84

assuming 2 rem of measured 30 to 250 keV photon dose, and there is .1 to 

2 MeV neutron dose for -- for five years. We also used the IREP Enterprise 

edition for calculating the POCs, and the doses were entered into IREP as 

normal distributions with a geometric standard deviation of 30 percent.

So, we compared our POC values to those listed in report 85. We 

found that this was a close comparison between what NIOSH calculated and 

what we calculated. We expected some differences since NIOSH used the 

Monte Carlo method and we just used average values. The majority of 

SC&A POC values were sent slightly less than NIOSH's and we had no 

findings or observations about their POC calculation.

For the dose-only values, we assumed the exposure of 1 rem for 

photon -- for the photon and neutron doses. Since we didn't use Monte 

Carlo methods, we didn't have to split doses into 500 -- measured in 500 

millirem (indiscernible). We used again the ice -- SC&A derived IGF values 

and DCF values to calculate the doses again for the dosimeters that were 

placed on the left -- left inner -- or left collar and left -- yeah, LCP -- I'm 

sorry -- for the A-P, the ISO, and the rotational geometry.

Doses were calculated again for the eight female and eight male 

organs. And based on a comparison to the NIOSH dose -- doses, we showed

a relatively close agreement. Again, some differences were expected 

because of the approach used. And most of -- again NIOSH's doses -- or 

SC&A's doses were slightly less than NIOSH doses. 

Since SC&A's IGF values for the A-P geometry were 1 for the batch 

locations, because the incident angle is -- is zero, we -- as part of our 

review, we checked the subset of the report 85 organ doses and found that 
85

in general 30 to 250 keV photon doses and neutron doses were at -- were 

within a few percentage points for all of the four batch locations. However, 

we did note that a few organs at badge locations NIOSH's AP doses differed 

more excessively -- more excessively than we were expecting, so that 

resulted in observation two.

In observation two, SC&A questions why NIOSH's A-P doses deviate 

beyond expected values. We did expect some small variance in doses 

because NIOSH used NMCP -- M -- MCNP and a 4-point averaging for the 

runs; however, for the male lung, we found that the variance was a little bit 

more significant than we expected. Same thing with the female lung, and 

for the male small intestine wall. And I should emphasize that we just 

looked at a small subset at the -- of this data, and we did identify a -- you 

know, those observations just by looking at a subset.

Okay. So, lastly SC&A evaluated the report 85 documentation, and we 

noted that NIOSH's explanation of their approach and method was relatively 

brief. It did rely on several supporting documents, so we needed to spend a 

relatively lengthy period of time understanding those documents and 

NIOSH's approach for using them. But we found that some of the key 

terminology to be a bit inconsistent and confusing, and that led to 

observation three. 

So, observation three states that NIOSH the terms "DCC" and "DCF" 

incorrectly. In report 85, there's an equation to 2.1, and they use DCC 

incorrectly because the dose conversion coefficients in ICRP 116, you 

actually have units of picogray per square centimeter, and that needs to be 

divided by the fluence conversion factor, which is shown in the -- in equation 
86

3-2 and 3-3 of report 69. So, therefore, we concluded DCC in equation 2.1 

should actually be DCF. 

And although we didn't cite this as an observation, we're just making a 

comment that we also felt that the title of report 69 appears to be incorrect 

because, again, ICRP 116 does not use the term dose conversion factor or 

DCF, which is used in the title of report 69. We think that maybe a more 

appropriate title would be updated ICRP 116 dose conversion coefficients 

and comparison to ICRP 74 dose conversion coefficients. 

So, in summary, SC&A evaluates an (indiscernible) approach used in 

85. We agree that using the ICRP 116 DCC values -- that it -- the IG-001 

Table 4.1A values are no longer valid, and it would be difficult to generate 

such a table. We had three observations.

The first was question why NIOSH's neutron IGF for several of the 

dosimeter locations differ from those in report 68. We also question why 

NIOSH's AP doses for a few cancers deviated beyond expected values and 

had some difficulty with the term DCC and DCF and they -- the use of those 

by NIOSH. So, do you have any questions? 

CHAIR BEACH: Thanks, Kathy. That was a good reporting on a 

complicated subject matter. Subcommittee members, any questions? 

MEMBER CASSANO: No. 

MEMBER VALERIO: No, Josie. 

MEMBER ZIEMER: None -- none here. 

CHAIR BEACH: Okay. So, I don't have any either except for what's 

the value, Kathy, would you say, of report 68 and 69 being reviewed? Are 

those on our list at some point? 
87

MS. BEHLING: They should be, I guess, on our list. They are not our 

list yet, but it's something that I will include in the future because as we get 

to the -- last time we had a long list of things that weren't reviewed, and we 

selected four -- I think four documents and there's still four remaining, so 

that's why I didn't add those this time, but I think it's worthwhile. 

CHAIR BEACH: Okay. 

DR. TAULBEE: This is Tim. Can I interject here? 

CHAIR BEACH: Sure, okay. 

DR. TAULBEE: First, I want to point out to the subcommittee that we 

have not implemented ICRP 116 yet, so that's important to keep in mind 

here in dose reconstruction in general. And second, report 85 was for 

informational purposes, you know, for us to begin to evaluate the effect of 

us implementing ICRP 116 and what effects it's going to have on our dose 

reconstruction process. We're still in the process of developing documents 

and methods for this, so I kind of feel like it's premature to be reviewing all 

this, but if you want to, okay. You know, that's okay. 

I do want to thank, you know, SC&A for the comments. I think they're 

-- they're quite good from the standpoint we're taking the observations 

under advisement as we do the implementation. At this time, we don't plan 

to respond to these observations directly because we haven't implemented 

the methodology yet. You know, again, we appreciate the comments, and 

we're taking them under advisement. 

You know, observation one, basically the results or the values in OTIB85 has the correct values of SC&A going back to and compared to our OTIB68, and those single point estimates appear to be an error just when you 
88

look at some of the figures in there. It's like, okay, we missed that in OTIB68, and we'll make that, you know, correction.

The other thing that's very difficult to do here is to compare point 

estimates to how this implementation's going to go, because we're using 

Monte Carlo method and looking at distributions and we're sampling from 

those distributions. So, you know, yes, you can look at point estimates and 

you'll come up fairly close. Sometimes will be close, sometimes you won't. 

It depends upon the shape of that that conversion coefficient. But that's 

something to keep in mind here. 

For observation two, you know, actually, you know, thanks to SC&A 

for pointing that out. We're going to look closer at that one because 

something doesn't look quite right there with the modeling, and we'll go 

back and look at it. But again, none of this has been implemented yet.

And as for observation three with the terminology, you're -- you're 

absolutely right, you know. And when we're going through the 

implementation, we'll be more cautious with our terminology and try and be 

very specific. I do take a little bit of exception to the title recommendation 

in the last slide. While they are correct, you know, neither ICRP-116 or 

one -- or 74 state dose conversion factors, they are dose conversion 

coefficients, we're not there directly comparing those two coefficients. We're 

actually comparing what we ended up using for organ doses. So, we'll work 

on a better title from that standpoint, but neither our title nor SC&A's 

recommendation is correct really. So, those are some of my initial thoughts 

here, and I guess I'd welcome feedback from the subcommittee on that. 

CHAIR BEACH: Okay. So, -- 
89

MS. BEHLING: (Indiscernible) -- 

CHAIR BEACH: Yeah, go ahead, Kathy. 

MS. BEHLING: Yeah. I'm sorry to -- to interrupt you. I also should 

just -- if you don't mind, like I said, this is a joint effort. I don't know if Ron 

Buchanan or Doug Farver have anything else to add to the presentation. I 

want to -- I should have given them maybe an opportunity to -- 

CHAIR BEACH: Yeah, I don't think anybody's shy; they probably 

would have, go ahead. 

MS. BEHLING: Okay. 

DR. BUCHANAN: This is Ron with SC&A. No, I have nothing to add to 

it. I do think that we should consider we seriously review 68 and 69 in light 

of what Tim said because these are very detailed documents, and they take 

a lot of time and resources to go through. And so, if they're going to be 

changing or not used in the near future, I would say, you know, I would 

wait, but then if there's something that they will be used as is for any 

changes in the future with OTIB-87, well, then we should review them. So, 

that would depend on that if they are going -- if they're outdated or if 

they're going to be revised. 

MS. BEHLING: And I agree with Ron. I would not -- 

CHAIR BEACH: Yeah. 

MS. BEHLING: Yeah, I'm sorry. I was not aware also of the -- the 

nature of those reports, and as Ron said, they're very, very detailed, and so 

perhaps we should put -- we should wait on those. 

CHAIR BEACH: Yeah, I was gonna suggest the same thing unless, 

Tim, do you have anything else to add? Are those going to be used as is or 
90

will they likely be changing? 

DR. TAULBEE: That's hard to say. They -- they very possibly could 

change as we're going through the -- right now we're working on the 

components of glove boxes, and so we're learning things as we're doing 

that, so, I guess, I would say kind of at this point they very well likely will 

change a little bit. So, you know, I just don't know right now from that, but 

as we get to the point of implementation, you know, we'll finalize all of these 

and, you know, then absolutely, you guys should review all of them. 

CHAIR BEACH: Okay. So -- so we don't expect an answer from 

NIOSH other than what Tim has told us today until ICRP-116 is 

implemented, and I'm sure you probably can't tell me when that's going to 

happen. I believe that was quite a ways down the road. I think we should 

put these in abeyance in our temporary BRS. 

UNIDENTIFIED SPEAKER: -- requested (indiscernible). 

CHAIR BEACH: Is that an agreement? 

MEMBER ZIEMER: I'm not even sure they're in abeyance. Are they --

are they -- 

CHAIR BEACH: Or open? 

MEMBER ZIEMER: Let's see, we're not -- we're not taking in any 

action on these observations, are we? 

CHAIR BEACH: No. NIOSH has indicated they're not going to answer 

these, they'll just keep in mind -- 

MEMBER ZIEMER: Right. 

CHAIR BEACH: And so, but we don't want to lose track of it either, 

so -- 
91

MEMBER ZIEMER: No, no, no. I'm thinking they're still in process or 

something like -- abeyance means we really have the final thing, we're just 

waiting for something -- well, I'm not sure what it is. It -- I guess it could 

be abeyance. 

CHAIR BEACH: You're probably correct, Paul. So, we can put them in 

process or if there's a better term, and just hold off until It's late a later 

date. 

MEMBER ZIEMER: Yeah. I don't -- I don't think we take -- we do 

anything until we hear officially from NIOSH. And as Tim said, that -- there 

-- they're not expecting to deal with these observations right now until they 

finish up their evaluation of 116. 

CHAIR BEACH: Correct. And I think we shouldn't also hold off on 

reviewing 68 and 69 at this time. 

MEMBER ZIEMER: Yeah. 

CHAIR BEACH: Okay. So, anything else for this topic? 

MEMBER VALERIO: So, Josie this is Loretta. Just for clarification, are 

these going to be flagged as in progress? 

CHAIR BEACH: Yeah, I think that's what we're just talking about. I 

believe that's correct. Is that correct, Kathy, we'll leave them -- 

MS. BEHLING: Yeah, that's -- 

CHAIR BEACH: -- in progress? 

MS. BEHLING: -- right. Yes, that's what I heard, in progress. 

CHAIR BEACH: Okay. So, we're ready for the next -- your handout,

preparation for the August meeting. 

MS. BEHLING: Yeah. 
92

PREPARATION FOR AUGUST 2023 MEETING

CHAIR BEACH: While you're getting that up, I was kind of 

brainstorming a presentation about what we've been doing for the last 

couple of years. 

(Whereupon, an unidentified speaker converses off the record on 

audio.)

CHAIR BEACH: I don't know how other subcommittee members feel. 

We've -- we've tackled quite a few of these old procedures. I don't know if 

it's time to do it presentation on what we've done, what we've accomplished. 

So far all's we've been doing is presenting documents for closure. We can 

continue to do that and not overburden Kathy. I -- I guess I'm looking for 

other thoughts from subcommittee members on -- on presenting to the 

Board.

MEMBER ZIEMER: This is Paul. I think we -- we certainly want to 

clean up all of the old ones and make sure that we're up to date on that. 

How -- is this list that you presented or that you distributed, Kathy, is that 

every -- all of the old ones? The ones that are labeled not yet presented, is 

that the complete list of all the old stuff? 

CHAIR BEACH: The only one -- 

MS. BEHLING: (Indiscernible) -- 

CHAIR BEACH: Kathy, the only one I couldn't find was the one you 

presented today, the OTIB-009. I found the -- 

MS. BEHLING: Yeah, I -- 

CHAIR BEACH: -- found the OVER-002, but not -- not the one from 

today. Is that just me not finding it, or? 
93

MS. BEHLING: No, the fact is that they're combined. And so -- 

CHAIR BEACH: Okay. 

MS. BEHLING: -- we listed one document, which is the overarching 

document, but that actually encompasses TIB-9. In the -- 

CHAIR BEACH: Yeah, that -- 

MS. BEHLING: -- BRS -- 

CHAIR BEACH: Yeah. Okay. That's what I thought. Did you want to 

put that document up on the screen? Right now, you're still showing 87. 

MS. BEHLING: Okay. I thought I was showing -- 

CHAIR BEACH: I don't know if anybody needs it up. I -- I have mine 

up. 

MS. BEHLING: Yeah, I was trying to show it. I don't know why I'm 

still showing something else here. 

CHAIR BEACH: it's nice to note on that five-page document the first 

two pages -- or the last three pages are complete, so we're definitely 

making progress. I think there's 18 left and I -- I'm sorry, but I wasn't --

didn't hear correctly if everything was on this list? 

MS. BEHLING: Are you seeing that or -- 

CHAIR BEACH: No. 

MS. BEHLING: -- not? Okay. Hold on just a second. Let me see if I 

can do this again. 

CHAIR BEACH: Now it's up. Perfect. 

MS. BEHLING: Okay. Great. All right. And you have -- 

MEMBER ZIEMER: And then I'm see -- I'm seeing 18 on the list, and 

that's really what I was asking. Is it -- are -- are those all of the, sort of, 
94

historic ones that haven't really gone up officially to the Board, those 18? 

MS. BEHLING: Yes. Yes. Yes, these 18. I was a also going to 

suggest that -- or you know, because I wasn't sure how -- what the outcome 

of the not suitable for matrix was going to be, we do have several here --

let's see, I have them marked -- that I'm showing here, like PROC-31, report 

5, PER-47, PER-5, and PER-49 -- no, that was presented. That was 

presented, I'm sorry. But those first four that I listed, perhaps we could add 

those to the one that I presented for you today unless, like you said, Josie, 

you want to go in a different direction and show progress that the 

subcommittee has been making? 

CHAIR BEACH: No, I think I'm with Paul. We can do that at a later 

time, maybe when we're complete -- I think it's more important to continue 

on through these and not overburden you with the extra reporting, and 

that's my thought now. 

MS. BEHLING: Okay. 

CHAIR BEACH: So, you're talking about doing 52, 55, the one today. 

I don't think I had them listed correctly. You're talking about the first four? 

MS. BEHLING: Actually I -- can you see my screen? 

CHAIR BEACH: Oh, yeah. Okay. 

MS. BEHLING: Okay. I'm -- 

CHAIR BEACH: -- looking on my own -- 

MS. BEHLING: -- these initially I did not identify as not suitable for 

matrix, so I thought perhaps we could finish those out before we delve into 

the not suitable for matrix. We'll do the one -- I was just doing the one that 

I present to you today, which will be pared down quite a bit, and then 
95

adding to that PROC-31, report 5, PER-47, and PER-5 that I'm -- 

CHAIR BEACH: Okay. And not -- 

MS. BEHLING: -- showing on -- 

CHAIR BEACH: And not -- 

MS. BEHLING: -- my screen? 

CHAIR BEACH: Did you -- no, not 49, okay. I would be okay with that 

with the preamble of the difference between the two so that the Board gets 

an idea of the difference between them. Other subcommittee members? 

MEMBER ZIEMER: What -- what was the -- so, I'm looking at the early 

ones particularly, but I -- when I look in the first page of your report, I see a 

couple from 2006. Actually, on the second page there's some from two 

hundred -- 2005 and 2007. Why wouldn't we do all of those early ones first?

MS. BEHLING: The -- 

CHAIR BEACH: Well, if you look to the -- to the right, some of them 

aren't suitable for matrix, and I think Kathy wanted to -- 

MEMBER ZIEMER: Oh, I -- oh, I got -- I got you. I see what you're 

saying. Yeah. 

CHAIR BEACH: -- is the easier one. 

MEMBER ZIEMER: Okay. Yeah, yeah. Okay. Yeah, I -- I'm with you. 

Okay. 

CHAIR BEACH: Yeah. 

MEMBER ZIEMER: Yeah, get those out of the way, yeah. And then 

you'll have a chance -- 

CHAIR BEACH: Yeah. 

MEMBER ZIEMER: -- to go back on those not suitable ones, okay, 
96

gotcha. 

CHAIR BEACH: Yeah. And then -- 

MEMBER ZIEMER: Okay. I'm fine. 

CHAIR BEACH: -- the Board -- yeah, since Kathy's already done the 

work on the not suitable ones, kind of give an explanation of that, and then 

moving forward at the next meeting, -- 

MEMBER ZIEMER: Yeah, yeah. 

CHAIR BEACH: -- the December meeting, maybe adding a few of 

those. 

MEMBER ZIEMER: Right. Okay. I'm good on that. Uh-huh. 

MEMBER VALERIO: So, this is Loretta. Kathy, what is the list of the 

items to be discussed in August? 

MS. BEHLING: Okay. The -- the one -- the overarching issue, that I -

- 002 that I discussed today, which will be reduced in length. Also PROC-31 

-- this is on the second page of my listing halfway down -- PROC-31, report 

5, PER-47, and PER-5. And, again, as I always do, if I find that it looks as if 

we could add something else or this is going to be too much, I will convey 

that to you, and we can make a decision to either reduce the number or add 

some more so that we fill up our hour or 90 minutes. 

CHAIR BEACH: Okay. 

MS. BEHLING: If that's okay. 

CHAIR BEACH: And if you are going to -- if we do determine, Kathy, 

that we're going to add more, we have to keep in mind -- I think you talked 

to Lori about helping with those documents, so probably need to figure that 

out earlier than later -- 
97

MS. BEHLING: Yes, -- 

CHAIR BEACH: -- so that you have the information available that you 

might need on those not suitables. 

MS. BEHLING: Okay. Yes, agreed. 

CHAIR BEACH: Okay. And we don't want to -- we don't want to go 

over 90 minutes, I think, with only a one-day meeting, so. 

MS. BEHLING: Yes, agreed. 

CHAIR BEACH: All right, any other comments? Okay. With that, I 

think we can move on to our last item, the newly issued guidance and 

supplemental topics. 

NEWLY ISSUED GUIDANCE AND SUPPLEMENTAL TOPICS

CHAIR BEACH: I don't think we got anything on that, correct? 

MS. BEHLING: No, (indiscernible) -- 

MEMBER CASSANO: No, I don't have that.

MS. BEHLING: Right. I'm going to see if I can share my screen here. 

Okay. This -- the reason I didn't issue a new one for this -- for this 

subcommittee meeting is because there's still some outstanding issues on 

the previous handout. And on this one, you have already tasked SC&A with 

the first two template reviews, which we are working on. I don't know if you 

want to add one or two to that. They're, you know, a little more complex 

than we have -- we can add to the DR templates a list of reviews. And I just 

want to make mention here at the end, we -- I had this list of -- let me get 

my -- for the last meeting we weren't tasked from this list with reviewing 

PER-40, PER-51, PER-67, and PER-83. But there are still four additional --

three PERs and one report that we did not -- we were not tasked to review. 
98

Those are PER-68, Electro Metallurgical Company, PER-70, which is Nuclear 

Metals, and PER-72, Seymour Specialty Wiring, and then lastly, report 60, 

which is neutron dose from highly-enriched uranium. So, those had not 

been tasked at the last meeting. 

CHAIR BEACH: Okay. Comments? 

MEMBER ZIEMER: I'm not sure how we quite decide that those are the 

ones -- Kathy, you've pointed out several here, but are those ones that 

SC&A's determined are more urgent or -- 

MS. BEHLING: No, I -- I -- 

MEMBER ZIEMER: -- mean, it's a pretty extensive list. How -- how 

are we deciding what to do, which -- which ones to look at? 

MS. BEHLING: Well, I -- I -- I simply go down through the list seeing 

what hasn't been -- been tasked yet, and these came up. It -- it -- no, I 

don't categorize them with regard to how urgent they are. I did list in the 

document summary what changes were made in these through these PERs. 

But they're just ones that we hadn't been tasked to review, and it seems like 

for the PERS, at least, we've been reviewing all of them. 

MEMBER ZIEMER: Yeah. Right. 

CHAIR BEACH: And I -- we did -- we did task some of the templates 

also, correct? That's not -- that's not on this list from the last -- 

MS. BEHLING: Yes. That's in the beginning here. You tasked us -- 

CHAIR BEACH: Okay. 

MS. BEHLING: -- with Amchitka Island and the Albuquerque 

Operations Office. 

CHAIR BEACH: Okay. 
99

MS. BEHLING: The -- the -- one of the things that I was thinking 

before you tasked more of these, I was hoping that we could make a 

presentation on how we approach these -- these reviews, since they're --

they're a little bit different. We have -- reviewing the template and the 

guidelines, and two or one or two cases associated with these. So, that 

report's going to look a little bit different. 

CHAIR BEACH: Right. 

MS. BEHLING: -- similar to our, like, PER task -- subtasks 4. But 

perhaps we could present those first and then you can determine if our 

approach for presenting or for reviewing those documents is appropriate 

before you task with additional -- 

CHAIR BEACH: Yeah. Yeah. I didn't -- I wasn't necessarily wanting 

to task. I was just -- just a reminder. 

MS. BEHLING: Yeah, that is on the -- 

CHAIR BEACH: Yeah, yeah. I'm fine with tasking, however, I don't 

want to get too far behind either. We have several reports, I think, 

upcoming that we haven't been presented yet, correct? 

MS. BEHLING: Yes. 

CHAIR BEACH: What we tasked the last time? 

MS. BEHLING: Yes, and they will likely be presented at the next 

meeting. 

CHAIR BEACH: Other subcommittee members, tasking, any thoughts? 

I feel like we can task (indiscernible) SC&A is capable of doing -- doing the 

work, or? 

MEMBER ZIEMER: Well, on PERs, since we task all of those eventually, 
100

it's advantageous just to do them in order by their -- by their date and just 

take a number then? I don't know how many you would want to task at a 

time, but, you know, I -- but Kathy, you had suggested several of those. 

MS. BEHLING: Yes, yes -- 

MEMBER ZIEMER: Are you listing them in order by date on your -- 

MS. BEHLING: Yes. 

MEMBER ZIEMER: I see the two '16s. Yeah. Certainly, the next 

group of those, we could task. I don't know how many at a time we've been 

doing in the past. Do you recall? 

CHAIR BEACH: I think four. 

MEMBER ZIEMER: Four? 

CHAIR BEACH: Yeah, well, -- 

MS. BEHLING: (Indiscernible) -- 

CHAIR BEACH: -- we tasked four. 

MEMBER ZIEMER: Well, how about the next four, and then on the 

other documents, how many more reasonable to look at now? 

MS. BEHLING: As -- and I'll just interject here. We were tasked with 

four PERs during -- in the February meeting, and there are three PERs that 

are still listed here that could be tasked today. The last one is a report. If 

we wanted to hold off on that until you look at and see some of the other 

reports that we were reviewing, that's -- you know, that's something to 

consider. But there are three PERs listed here that you may want to task. 

MEMBER ZIEMER: Is that 067, 68, and 70? Are those the three 

you're talking about? 

CHAIR BEACH: 72. 
101

MS. BEHLING: Yeah. It's -- yeah, 68, 70, and 72. The first three on 

that list, we were tasked with during the last time. And we were --

MEMBER ZIEMER: Oh, okay. 

MS. BEHLING: -- PER-83, because it was two Weldon Springs, and we 

wanted to keep them together. 

MEMBER ZIEMER: Yeah, gotcha. Yeah. 

CHAIR BEACH: And then 60 is the report, correct? 

MS. BEHLING: Correct. 

CHAIR BEACH: Okay. Oh, there it is. I see it. Can you move that up 

just a little bit, Kathy? 

MS. BEHLING: Can you see it now? 

CHAIR BEACH: Yeah. I'm fine with tasking all four, Paul. If you'd 

rather just stick with PERs, that’s fine also. 

MEMBER ZIEMER: No, no, no. I wasn't trying to stick with just PERs. 

I just wanted to say we're gonna do those eventually, how many do we do 

at a time, then add to that what we can handle here. 

CHAIR BEACH: I'm thinking Kathy, you're not going to suggest more 

than SC&A can handle; is that correct? 

MS. BEHLING: That's correct. Yeah. 

CHAIR BEACH: Okay. Rashaun, any problems with that, assigning 

those four that we've been discussing? 

DR. ROBERTS: No, none at all. 

CHAIR BEACH: I would say we go ahead and task 68, 70, 72, and 

report 60 at this time then. 

MS. BEHLING: Okay. 
102

CHAIR BEACH: The only other thing I'm going to add, in prepping for 

this meeting, sometimes more information is better. So, if there's emails, if 

you send them to one person, if you could send them to the whole 

subcommittee, and Kathy, this one probably would have been fine to refresh 

us with -- with this. Even if it wasn't updated, just so that we have it in our 

folder of -- of items for this meeting. 

MS. BEHLING: Yes, I agree. I apologize for missing this one -- not 

including it. 

CHAIR BEACH: No, that's okay. I -- just for the future, just better to 

have it all together, at least for me, I know. Any other items before we talk 

about the next meeting? Okay. Let's talk about the scheduling our next 

meeting. And, please, interject what your thoughts are. Three months? 

four months? What we're -- what you're thinking for prep? 

MEMBER ZIEMER: When was the -- 

MEMBER CASSANO: So, Josie, -- 

MEMBER ZIEMER: -- last meeting? We -- 

MEMBER VALERIO: Josie, this is Loretta. 

MEMBER ZIEMER: -- February -- 

CHAIR BEACH: Yeah. 

MEMBER ZIEMER: -- about four months is about right, isn't it? 

CHAIR BEACH: I -- I would say so. Loretta, did you have a comment? 

MEMBER VALERIO: Yeah, I was gonna say probably about four 

months apart. Four, yeah. Four, because we have the full-Board meeting in 

August, so four months would put us right about the right time frame for the 

next meeting for the subcommittee. 
103

CHAIR BEACH: Yeah, that's puts us into October, and I'm going to be 

gone the whole month of October, so that would go -- we would have to go 

into November. So, everybody, check your calendars for November. I 

guess, Rashaun, I can turn this over to you. 

MEMBER CASSANO: Sure. 

CHAIR BEACH: And I'm thinking the first or second week of --

probably the second week of November so I have time -- because I'm going 

to be out of the country for the whole month of October. 

DR. ROBERTS: Okay. And are we still wanting to keep to a 

Wednesday or Thursday, because that would be the eighth? or ninth? 

CHAIR BEACH: That -- Wednesday, so any time’s good with me. So, 

whatever's good for everybody else. Wednesday and Thursday is fine. 

MEMBER CASSANO: Yeah, Wednesday or Thursday are -- Tuesday 

isn't bad either, but that week election day is Tuesday, so that's all -- out. 

Yeah, Wednesday or Thursdays are best for me. 

DR. TAULBEE: Could I put a plug in for Thursdays over Wednesdays? 

This is Tim. 

CHAIR BEACH: Sure. 

DR. TAULBEE: It's not critical, but it certainly helps us a little. 

CHAIR BEACH: Sure. Yeah. And the ninth or the 16th, any 

preference there? 

DR. ROBERTS: Actual -- yeah, go ahead. 

MEMBER CASSANO: Not really. 

MEMBER ZIEMER: I'm good for either one, Josie. 

CHAIR BEACH: Okay, I'm good for either, too. 
104

MEMBER VALERIO: I'm good for either, too. 

DR. ROBERTS: So, November 16th, at 11:00 a.m., Eastern. 

CHAIR BEACH: Okay. 

DR. ROBERTS: Okay. I think we have that set then, so Thursday, 

November 16th, starting at 11:00 a.m. 

CHAIR BEACH: Okay. So, I think that wraps up this meeting. Thank 

you everyone for the hard work.

(Whereupon, the meeting was adjourned at 2:58 p.m. EDT).